Shearman & Sterling’s Christopher LaVigne and Danforth Newcomb (both New York-Litigation) co-authored an article, titled “A New Tool for Extraterritorial Sanctions Enforcement,” that was published by Law360 on April 22.

The article discusses the Department of Justice’s latest criminal enforcement actions in the sanctions arena. Relying on a theory of “facilitation,” the DOJ recently obtained a guilty plea from a multinational manufacturing corporation, based on the oversight practices of its U.S. business segment. Unlike DOJ’s past criminal charges against financial institutions for “stripping,” DOJ’s latest case outlines a new theory and potential set of targets. As a result, the authors say, “Prudent multinational corporations must both understand the scope of the DOJ’s newest tool and adopt and implement compliance programs that will be effective in avoiding violations in this area.”

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