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Compliance Hot Spots: Sanctions Are 'The New FCPA,' 

May 04, 2022

Partner Giovanna Cinelli spoke with’s “Compliance Hot Spots” regarding Deputy Attorney General Lisa Monaco’s remarks on sanctions during a New York City Bar Association conference. 

After emphasizing that it was critically important for multinationals to assess how the sanctions will affect their business, Monaco said that “one way to think about this is as sanctions being the new [Foreign Corrupt Practices Act].”

“I think it’s something to make companies sit up and take notice,” Giovanna remarked in the column. “But having said that, I think it’s obvious to anybody who reads the newspaper that sanctions are here to stay for a long time, given the nature and depth of the way sanctions have been implemented. It’s going to take a long time to peel the layers to eliminate or refine all the restrictions that have been put in place. It is highly likely that the U.S. Government will continue to enforce sanctions violations assertively based on the foreign policy and complex nature of the restrictions.”

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