The U.S. declined to prosecute a Massachusetts biochemical company that was part of an illegal export scheme involving China, the first time DOJ’s National Security Division has offered a corporate declination under its recently updated voluntary self-disclosure program.
A U.K. law firm this week warned about sanctions risks tied to property purchases, saying one of its lawyers had to first obtain approval from a U.K. bank before a British-Iranian client could buy property in the U.K.
DOJ last week announced a set of new charges, arrests and forfeiture proceedings to mark the second anniversary of Russia’s invasion of Ukraine. The agency announced forfeiture actions involving $2.5 million in luxury properties, arrested two U.S. residents for helping a Russian violate sanctions, charged two sanctioned oligarchs with violating U.S. restrictions and more.
Businesses and industry lawyers should expect to see an increase in Foreign Corrupt Practices Act enforcement this year, especially as DOJ more frequently uses data analytics to find possible violations, said Dan Kahn, the former chief of DOJ’s FCPA unit.
The U.S. fined German software company SAP SE more than $200 million for violating the Foreign Corrupt Practices Act, saying it bribed government officials in South Africa, Malawi, Kenya, Tanzania, Ghana, Indonesia and Azerbaijan to secure business contracts. The company agreed to a nearly $100 million settlement with the SEC and faces a $118.8 million criminal penalty, along with a forfeiture, as part of a deferred prosecution agreement with DOJ.