White Deer Management (White Deer), a private equity firm headquartered in Houston, has obtained a declination following self-disclosure of violations of sanctions and export laws committed by a recent acquisition. The settlement is the first of its kind under the M&A safe harbor provisions of the DOJ National Security Division Enforcement Policy for Business Organizations (Policy). In its pre-closing due diligence of Unicat Catalyst Technologies, a supplier of catalyst products used in petrochemical refining and steel mills based in Alvin, Texas, White Deer missed a crucial document. As a result, the firm was unaware of Unicat’s dealings with customers in Iran, Syria, Cuba and Venezuela until well after the deal closed. This article offers a close look at how the Policy functions in practice and the compliance takeaways for private equity firms and other acquirers. See “Safe Harbor Policy Seeks to Encourage Self-Reporting of Issues in M&A Transactions” (Oct. 11, 2023).