Benjamin A. O'Neil

Jan 31, 2024 | lexology.com | Patrick Rowan |Alex Brackett |Benjamin A. O'Neil |Alex Scandroli

For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its officials, oligarchs and Russia’s financial and energy industries, among others.

Feb 27, 2023 | lexblog.com | Noreen P. Kelly |Benjamin A. O'Neil |Casey Erin Lucier |Edwin Childs

On Feb. 22, 2023, U.S. Attorneys’ Offices throughout the country adopted a new policy that incentivizes corporate voluntary self-disclosure of misconduct. Deputy Attorney General Lisa Monaco’s Sept. 15, 2022 memorandum (“Monaco Memo”) instructed all DOJ sections to review their policies incentivizing corporate voluntary self-disclosure or, if no formal written policy existed, to draft and publish such policies. The U.S. Attorneys’ Offices’ new, uniform policy fulfilled the Monaco Memo’s directive.