There is no more important federal priority than the war against global terrorism. In this battle, federal agencies and law enforcement offices are utilizing every weapon in the arsenal. In our last column, we wrote about how the U.S. Treasury Department uses its broad anti-money laundering powers to combat global terrorism and rogue states and banks. In this column, we discuss how a recent prosecution demonstrates that the U.S. Department of Justice (DOJ) similarly uses anti-corruption laws to attack indirectly overseas security threats that it cannot necessarily attack directly. The message to multinationals that deal in sensitive materials and their counsel is not only to know your customer, but also to know that the U.S. will closely monitor these markets and use its laws to the maximum extent. Moreover, firms must be wary that questionable transactions that appear to be about corruption and money may actually be about something far worse.
Last month, using federal money laundering statutes, the DOJ secured the conviction and four-year sentence of an official with Rosatom, Russia’s state-owned nuclear corporation. Rosatom controls every aspect of the Russian nuclear complex, including the sale of nuclear material. The Rosatom official pleaded guilty to receiving $2 million in bribes to steer Rosatom contracts to a U.S. vendor. A principal of the vendor pleaded guilty to Foreign Corrupt Practices Act and wire fraud charges.
