DOJ Is Evolving Its Focus and Encourages Companies to Join 

Deputy Attorney General Lisa Monaco urged companies to evolve their thinking on sanctions compliance as “the new FCPA” and stressed the deepening intersection of corporate crime and national security during a recent address to the NYC Bar Association’s 10th Annual White Collar Crime Institute. The Russian invasion of Ukraine has pushed export-sanctions enforcement to center stage at DOJ and Monaco recommends that all companies, even those outside the financial sector, sharpen their attention on sanctions accordingly. Monaco and Andrew Adams, co-chief of Task Force KleptoCapture, explained the importance of the new task force announced by the Biden administration in March 2022 and its direct connection to U.S. national security. We share their insights on the DOJ’s enforcement priorities. See our four-part series on the Monaco Memo: “A Roll Back on Individuals and Cooperation” (Jan. 19, 2022); “A Shift in the Monitorship Cost/Benefit Analysis” (Feb. 2, 2022); “Considering All Prior Misconduct” (Feb. 16, 2022); and “The Corporate Crime Advisory Group” (Mar. 2, 2022).

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