The U.S. Department of the Treasury told companies that it "understands" they may be running into issues covering their compliance bases amid the global pandemic and that if a shift in resources leads to a violation, the government will take that into account in any eventual enforcement. As such, companies may respond by "reallocating" sanctions compliance resources. Alexis Coll-Very, a partner in Goodwin’s Securities + Shareholder Litigation and Government Investigations + Enforcement practices who advises companies on government enforcement, saw the move as a positive one in that it recognized the difficult realities that companies are facing. Read the article in Law360 here.
In The Press April 20, 2020