What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael Volkov unpacks the fascinating DOJ-led global enforcement action against UNICAT Catalyst Technologies - a case that reflects the U.S. government's intensifying focus on trade enforcement across sanctions, export controls, and customs. This resolution marks the first declination under DOJ’s National Security Division M&A policy, showcasing the power of voluntary disclosure, cooperation, and remediation in today’s enforcement environment.

You’ll hear him discuss:

• How DOJ, OFAC, BIS, and CBP coordinated parallel resolutions against UNICAT
• The $3.3 million forfeiture and additional penalties tied to underpaid duties and unlawful exports
• Why DOJ declined prosecution of UNICAT’s parent company, White Deer, under its M&A policy
• The former CEO’s role in orchestrating 23 unlawful sales to Iran, Venezuela, and Cuba
• The importance of identifying willful intent in sanctions violations — and when DOJ disclosure is required
• The risks of failed pre-acquisition due diligence and the value of strong post-acquisition integration
• How concealment tactics like falsified invoices and coded emails were used to hide dealings with sanctioned entities
• Key lessons for global companies navigating the new era of trade compliance and enforcement

Resources

Michael Volkov on LinkedIn | Twitter

The Volkov Law Group