Sanction
s continue to be a dynamic area of regulation and enforcement. In its first year, the Biden Administration has already undertaken a number of different sanctions initiatives. The three examples below highlight the range of strategies employed and their potential ramifications for private investment funds.
Office of Foreign Assets Control
To Disclose or Not to Disclose: Navigating the Complex Relationship Between Voluntary Self-Disclosure of Sanctions Violations and Enforcement Response
By Seetha Ramachandran & Lucas Kowalczyk on
In the ever-evolving and complex world of economic sanctions, voluntary self-disclosure is frequently the best long-term strategy for any company that discovers a violation of a sanctions regime. The more difficult task is to assess the costs and benefits of self-disclosure in cases where the conduct falls into a gray…