On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm and its affiliates following the firm’s voluntary disclosure of sanctions- and export control-related violations involving an entity the firm acquired in 2020.  The watershed announcement marks the first application of the voluntary self-disclosure safe harbor provision from the DOJ’s Mergers and Acquisitions Policy (“M&A Policy”) adopted in March 2024.

Over the past week, the United States, European Union, United Kingdom and several other countries imposed rounds of sweeping new sanctions on Russia in response to its invasion of Ukraine. Between February 21 and 23, 2022, the U.S., EU, U.K., Japan and Australia announced an initial round of sanctions after Russia officially recognized two Russian-backed separatist regions of eastern Ukraine—the so-called Donetsk and Luhansk People’s Republics (respectively, “DNR” and “LNR”), and then deployed troops to these regions. The first wave of sanctions targeted Russian sovereign debt, several Russian banks, and a number of Russian “elites” and officials, including Russian Defense Minister Sergei Shoigu. The measures additionally included a trade and investment embargo on the two separatist regions—similar to existing restrictions on Crimea. Germany also announced that it would halt certification of the Nord Stream 2 natural-gas pipeline. The U.S. followed with sanctions on Nord Stream 2 AG, its CEO, and its corporate officers on February 23, 2022.