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Monaco emphasizes sanctions as a top DOJ commitment in "the new FCPA."

The ongoing Russian invasion of Ukraine is top of mind for the Department of Justice, which has prioritized efforts to thwart sanctions evasion.

In a moderated discussion at a New York City Bar Association event on Wednesday, Deputy Attorney General Lisa Monaco reiterated this focus. She said that the Justice Department is committed to enforcing the sanctions that the US has imposed on Russia in the two months since it first invaded Ukraine, and that financial institutions and international corporations must pay close attention to the actions taken to avoid falling foul of the agency.

According to the Wall Street Journal, Monaco stated, "One way to think about this is as sanctions being the new FCPA."

The Foreign Corrupt Practices Act has long been the Department of Justice's most potent weapon in the fight against white-collar crime. Many high-profile enforcement actions have resulted from the law's extraterritorial reach in combating bribery and corruption, including a $52.5 million criminal penalty announced last week against international waste management company Stericycle.

Hearing Monaco mention the FCPA in relation to the Justice Department's focus on enforcing sanctions against Russia should pique compliance officers' interest, particularly in the financial services industry. Last month, the agency formed Task Force KleptoCapture to investigate and prosecute sanctions violators, including institutions that unwittingly provide those who are barred with a way to circumvent the restrictions.

At the time, Attorney General Merrick Garland stated, "We will leave no stone unturned in our efforts to investigate, arrest, and prosecute those whose criminal acts enable the Russian government to continue this unjust war. Let me be clear: If you violate our laws, we will hold you accountable."



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