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DOJ Announces First “Near Miss” Non-Prosecution Agreement Under Its 2026 Corporate Enforcement Policy
11/03/2026
On October 27, 2026, the U.S. Department of Justice (“DOJ”) announced that its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Eastern District of North Carolina had entered into a non-prosecution agreement (“NPA”) with a networking equipment company based in North Carolina.
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Private Equity Firm Pays Over $11 Million To Settle Russia-Related Sanctions With OFAC
12/17/2025
On December 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced an $11,485,352 settlement with a Chicago-based private equity firm (the “Company”) to resolve alleged violations of Ukraine- and Russia-related sanctions due to continued indirect investment by the Company on behalf of a Russian oligarch, Suleiman Kerimov, designated by OFAC as a Specially Designated National (“SDN”) in 2018.
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Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products
12/11/2024
On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s Specially Designated Nationals and Blocked Persons list (“SDN list”). Van Loon, et al. v. Dep’t of Treasury, et al., No. 23-50669, — F.4th — (5th Cir. Nov. 26, 2024).