Justice Department Urges Companies to Self-Report Sanctions Violations

The Justice Department is looking to enlist the private sector in its efforts to enforce U.S. sanctions on countries such as Russia, a top official said.

The agency has long worked to police the restrictions that the U.S. has placed on countries such as Iran or North Korea, but it has dialed up its efforts following Russia’s invasion of Ukraine, Deputy Attorney General Lisa Monaco said Thursday.

The Justice Department is adding resources and looking for new ways to enforce sanctions, said Ms. Monaco, who spoke via video at a conference hosted by Global Investigations Review in London.

The agency has also created specialized task forces to increase collaboration across the U.S. government and with allies abroad, she said.

“The fact that we are putting all these resources into our sanctions enforcement is something that I think you should pay particular attention to,” Ms. Monaco said. “This is a signal that we’re really focusing on new ways of sanctions enforcement.”

At Thursday’s event and in other recent speeches, Ms. Monaco has compared the Justice Department’s increased focus on sanctions enforcement to its enforcement of the Foreign Corrupt Practices Act, an antibribery law.

Federal prosecutors in the early 2000s began aggressively enforcing the FCPA, and the law has since become one of the Justice Department’s most successful white-collar enforcement programs, garnering billions of dollars in fines against multinational corporations.

As it does with its FCPA enforcement, the Justice Department is looking to companies to play a role in helping ensure U.S. sanctions are effective, Ms. Monaco said. The department in 2016 created a program that offers leniency to companies that disclose potential sanctions or export controls violations and cooperate with prosecutors. The program was revised in 2019.

“What we actually are doing is aiming for our sanctions enforcement to incentivize companies to come forward and to voluntarily disclose discovered misconduct,” Ms. Monaco said. “The number of voluntary self-disclosures in this particular area has been increasing” since the agency created the leniency program, she said.

“For any company that thinks it may have a sanctions problem, our message is unequivocal,” Ms. Monaco said. “Pick up the phone and call us—don’t wait for us to call you.”

Article credit: https://www.wsj.com/articles/justice-department-urges-companies-to-self-report-sanctions-violations-11655410956