When US Deputy Attorney General Lisa Monaco in June 2022 called sanctions “the new FCPA” (Foreign Corrupt Practices Act), the practicing bar braced for impact. In the months that followed the declaration, US authorities have issued a stream of new export controls and sanctions (together “export”) measures to address evolving geopolitical situations and have announced record-setting penalty settlements. We highlight key trends and look ahead to how companies can manage evolving export enforcement risks. Enforcement Trends Export cases often are settled without penalties or public notice. There are signs that the rhetoric of senior officials around export enforcement is beginning to match
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