A Criminal Resolution Is Not A Global Conclusion

Most corporations, especially those operating globally and in challenging jurisdictions, consider government enforcement actions to be one of their most significant areas of legal risk, and rightfully so, as the US Department of Justice (DOJ), the US Treasury’s Office of Foreign Assets Control (OFAC), and other US government entities have the power to institute far-reaching investigations, impose burdensome monitorships, and extract significant monetary penalties for violations of a variety of statutes and regulations. But what many companies fail to realize is that a resolution with the US government is not global, and significant risks may lie in derivative actions in other jurisdictions or civil forums.