DOJ Spotlights Voluntary Self Disclosure in M&A as it Adapts to New National Security Threats

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The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen during my time in government: the rapid expansion of national security-related corporate crime.” From the first-ever criminal resolution for sanctions violations from illicit sales and transport of Iranian oil by Suez Rajan Ltd. to guilty pleas and $4.3 billion in penalties by Binance and CZ related to sanctions and anti-money laundering, the Department of Justice has been on a roll, and it doesn’t appear to be slowing down any time soon. The good news for corporations is that even as the stakes rise to implicate national security, the Department continues to incentivize and reward corporate responsibility.