As the DOJ’s commitment to sanctions enforcement grows, the stakes are potentially very high. As Deputy Attorney General Monaco explained, the old ways of managing sanction risks may no longer be sufficient to address the sanctions risks of today. Companies should act to assess their current sanctions compliance programs and risk profile to reduce the risk of potential violations and DOJ enforcement.
To learn more about the implications of Deputy Attorney General Monaco’s remarks, please contact any of the authors or your usual DLA Piper contact.