In part one of Cari’s Legal Exchange, Cari Stinebower and partner and former U.S. Attorney for the District of Columbia Matt Graves discuss how companies can navigate evolving DOJ voluntary disclosure programs, the importance of compliance, and the growing focus on individual accountability in corporate investigations.

Effective September 29, 2025, many thousands of additional non-U.S. entities around the world are now prohibited from receiving U.S. goods, software, and technology under an “affiliates” interim final rule (the IFR) published by the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce.  

On September 27, 2025, the United Nations reimposed sanctions and other restrictions based on Iran’s continuing “significant non-performance” of its nuclear commitments. Today, September 29, following the UN resolution, the European Union formally reimposed a broad range of sanctions on Iran, citing the same “significant non-performance” of its nuclear commitments under the Joint Comprehensive Plan of Action (JCPOA). These actions follow the invocation of the JCPOA’s snapback mechanism by the E3 (France, Germany, and the United Kingdom) on August 28, 2025, and mark a major shift in the international legal and commercial landscape for entities engaged with Iran.