Are Recent Export Controls Enforcement Actions Low-Hanging Fruit or a New Wave of Prosecutorial Zeal?

The summer of 2024 saw a cluster of DOJ enforcement actions targeting individuals who violated export controls laws by shipping products to Russia, sometimes by circuitous routes. These cases may leave some wondering whether they are just quick wins against bit players or the modest first steps of a more aggressive – and coordinated – pursuit of a spectrum of bad actors bent on helping adversaries like Russia to access sensitive technologies. The Anti-Corruption Report spoke with practitioners about their impressions of these recent events, what these developments signal for the DOJ and other federal enforcement authorities’ priorities, and the implications on corporate due diligence efforts. See “Measures Against Russia Pose Serious Compliance Challenges” (Sep. 27, 2023).

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