Welcome to Compliance Hot Spots, our weekly snapshot on white-collar, regulatory and compliance news and trends. It's been a quiet week on the legal front in D.C., but we had to find something to fill the newsletter. (Check out my colleague Marcia Coyle's coverage of "the leak" here.) Today, we examine the impact of sanctions enforcement emerging as potentially DOJ's top corporate enforcement priority. Plus, the SEC is expanding its crypto enforcement section and Elon Musk is jumping into a Supreme Court fight over SEC gag orders. Please reach out with tips and feedback. Contact me at [email protected] and @AGoudsward on Twitter.

Lisa Monaco, Deputy Attorney General at the U.S. Department of Justice, testifies before the Senate Judiciary Committee during a hearing entitled "Renewing and Strengthening the Violence Against Women Act," on October 5, 2021. Photo: Diego M. Radzinschi/ALM

Russia Sanctions Are 'The New FCPA'

To stress the importance of the DOJ's efforts to enforce newly imposed Russia sanctions, Deputy Attorney General Lisa Monaco used a comparison that would be instantly familiar to the room full of white-collar lawyers she addressed last week in New York City.

After emphasizing that it was "critically important" for multinationals to assess how the sanctions will affect their business, Monaco told an audience at a New York City Bar Association conference that "one way to think about this is as sanctions being the new FCPA," according to a Wall Street Journal report.

The increased use of the FCPA has, of course, transformed the white-collar bar in recent years, leading to some of DOJ's largest ever penalties against major corporations and strengthening ties between DOJ prosecutors and their foreign counterparts, particularly in Latin America. FCPA defense has also become a lynchpin of white-collar practices in Big Law.