The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

Volkov – Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate enforcement program, akin to the FCPA, no new corporate cases were brought on the sanctions front.