Sharon Cohen Levin, a partner, and Andrew DeFilippis, a special counsel, both in the Firm’s Criminal Defense and Investigations Group and its National Security Practice, discussed the DOJ’s new corporate criminal enforcement priorities, and revisions to the DOJ Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), in New York University School of Law’s Compliance & Enforcement Blog.
Sharon and Andrew analyzed the significance of the Department’s identification of tariff evasion and customs fraud as its #2 criminal corporate enforcement priority, which they noted signals that the administration will aggressively ensure compliance with recent trade measures. They also discussed converging compliance risks on companies’ global supply chains and enforcement authorities’ heightened focus on flows of goods and technology.
The authors noted that financial institutions will also be affected by the new enforcement priorities, including “banks and other financial institutions involved in providing financing, payment processing, or other financial services associated with international trade, [as] regulators will expect them to enhance their controls to address tariff evasion schemes and related typologies.”
Read: “White Collar Experts Discuss New DOJ Criminal Enforcement Priorities”