Expect Exponential Growth In DOJ Sanctions Enforcement

The temperature is rising at the Department of Justice as the Biden Administration has outlined how the department will crack down on corporate misconduct. One major step will be a "new level of intensity and commitment to sanctions enforcement," or what Deputy Attorney General Lisa Monaco calls the "new" Foreign Corrupt Practices Act.

Monaco used the growth of Foreign Corrupt Practices Act (FCPA) enforcement as an example of how a little-used statute can become the most powerful weapon in DOJ's corporate enforcement arsenal. She expects to see the same level of exponential growth in sanctions enforcement activity.

Monaco explained the reasons for the new focus on sanctions enforcement, stating that the "geopolitical landscape is more challenging and complex than ever" and "corporate crime increasingly implicates national security."