‘The new FCPA’: Monaco stresses sanctions as top DOJ commitment

Deputy Attorney General Lisa Monaco reiterated this focus as part of a moderated discussion at a New York City Bar Association event Wednesday. As part of her remarks, she noted the Justice Department is committed to the enforcement of sanctions the United States has placed on Russia over the course of the last two months since it first invaded Ukraine and that financial institutions and international corporations must pay close attention to the actions taken to avoid running afoul of the agency.

“One way to think about this is as sanctions being the new FCPA,” Monaco said, according to the Wall Street Journal.

The Foreign Corrupt Practices Act has long been the Justice Department’s most threatening weapon to fighting white-collar crime. The law’s extraterritorial reach in cracking down on bribery and corruption has resulted in many high-profile enforcement actions, including a $52.5 million criminal penalty announced last week against international waste management company Stericycle.

To hear Monaco invoke the FCPA when discussing the Justice Department’s focus on enforcing sanctions against Russia should catch the eye of compliance officers, particularly those in the financial services industry. The agency last month established Task Force KleptoCapture to investigate and prosecute sanctions violators, including the institutions that unwittingly provide those individuals or entities blocked with a path to avoiding the restrictions upon them.

“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,” said Attorney General Merrick Garland at the time. “Let me be clear: If you violate our laws, we will hold you accountable.”