White Collar Update: 4 Developments To Watch

Steve Fagell’s commentary was included in a Law360 article examining developments around enforcement actions taken by the Department of Justice (DOJ) and how they might unfold in the second half of 2024. Steve comments the DOJ's National Security Division decision to decline charging MilliporeSigma with trade control crimes after the life sciences firm voluntarily disclosed a former employee's scheme to illegally export products to China.

"The National Security Division has now dipped its toe in the declination waters, and it will be interesting to see whether they take the plunge," Steve said. He adds that the case serves as a "significant development" and "data point" for companies considering voluntary disclosure.

Steve also pointed out that "the NSD has now moved beyond saying that a declination was a possibility to actually giving a declination. That's an encouraging sign for companies that may be considering a voluntary disclosure — and it's definitely something to watch in the export controls and sanctions space.”

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