New US Enforcement Focus Could Lead to 'Previously Unseen' Compliance Risks, Law Firm Says

Companies should expect the U.S. to devote “higher budgets” and increase interagency coordination to bolster U.S. sanctions and export control enforcement, which could lead to “previously unseen” compliance risks, Orrick said in a recent client alert. The firm pointed to DOJ’s plans to hire new export control and sanctions prosecutors (see 2303070023), the administration’s new disruptive technology strike force (see 2303220037), the joint compliance alert earlier this year that outlines methods Russia uses to circumvent trade restrictions (see 2303020054), and more.

Companies should be adapting their “compliance arrangements to the federal government’s new prioritization of export controls and sanctions enforcement,” Orrick said. “It is especially important to ensure that international trade compliance programs and compliance training programs are sensitive to the variety of new, complex restrictions regarding China and Russia.” Trade lawyers are specifically expecting a sharp increase in DOJ export control and sanctions prosecutions in the coming months as the agency’s Counterintelligence and Export Control Section undergoes a hiring spree (see 2303200051).