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DOJ Sheds Light on Evaluation of Corporate Compliance Policies

Client Alert | less than 1 min read | 02.24.17

On February 8, 2017, DOJ Fraud Section issued new guidance on the Evaluation of Corporate Compliance Programs. This guidance, discussed more fully in our blog, serves as a useful framework for compliance professionals in crafting and strengthening corporate compliance policies, corporate officers and directors who want to ensure their compliance program meets the DOJ’s expectations, and counsel to use in navigating communications and disclosures to the DOJ Fraud Section.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....