USA – WASHINGTON, DC Trends and Developments Contributed by: Jonathan M. Epstein, Daniel E. Goren, Tahlia Townsend and Manny Levitt, Holland & Knight LLP
Although these actions signal an intent by DOJ to increase their focus on sanctions violations, particu - larly by corporations, it is notable that, on the same day as the 12 May Memo, DOJ’s Criminal Division also published a new Corporate Enforcement and Volun - tary Self-Disclosure Policy (CEP) establishing a policy under which it will be generally easier for companies to avoid criminal prosecution if they voluntarily dis - close potential sanctions violations, cooperate with DOJ investigations, and mitigate harm. Other Policy and Enforcement Developments Other significant policy changes announced thus far in 2025 include the following. An unannounced and unofficial pause on sanctions designations related to the Russian Federation since President Trump took office. However, comments by President Trump and Trump Administration officials suggest that this policy may be temporary. Members of Congress have also introduced legislation that appears to have significant support and, if passed, could trigger additional sanctions on Russia. Fur - thermore, despite the absence of new Russia-related designations, OFAC continues to pursue enforcement actions related to Russia. Indeed, four of seven set - tlements announced by OFAC so far in 2025 involve Russia-related violations, including a USD215 million dollar settlement with a venture capital firm for alleg - edly managing an investment for a sanctioned Rus - sian oligarch, and two one million dollar settlements for alleged export of industrial equipment to Russian SDNs and allegedly assisting SDNs to evade sanc - tions by transferring ownership of luxury condomini - ums to non-sanctioned family members and associ - ated shell companies.
The Trump Administration’s revocation and rescission of the West Bank Sanctions Program, implemented under President Biden, target persons determined to be undermining peace, security, and stability in the West Bank. The Trump Administration’s implementation of a new sanctions program targeting prosecutors, judges and other persons affiliated with the International Criminal Court (ICC) in response to the ICC’s issuance of arrest warrants and filing of charges against Israeli officials after the Israeli military’s response to Hamas terrorist attacks on 7 October, 2023.
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