# Companies Screen Cross-Border Acquisitions

The Volkov Law Group podcast warns that acquiring a foreign business can bring its existing operations within U.S. jurisdiction and create immediate sanctions exposure, including under the Cuba and Iran sanctions programs. For government contractors and other firms pursuing cross-border acquisitions, the issue can affect transaction diligence and post-close controls: the signal advises testing transaction data and controls after closing, escalating red flags, and accounting for the DOJ’s 180-day disclosure and one-year remediation windows when addressing potential violations.

- Companies pursuing foreign acquisitions should include sanctions-specific diligence and review of acquired transaction data and controls in their acquisition process.
- Contractors should establish a process to escalate potential sanctions red flags after closing; inherited operations may create U.S. exposure even when they were previously outside U.S. jurisdiction.
- The signal identifies DOJ disclosure and remediation windows as relevant to response planning. The summary does not characterize disclosure as mandatory.

**Jurisdictions:** federal
**Topics:** Regulatory Compliance
**Published:** October 11, 2026

### Government Entities
- Office of Foreign Assets Control (OFAC)
- U.S. Department of Justice (DOJ)

### Sources
- [Episode 456 -- Buying a Sanctions Violation | The Volkov Law Group - JDSupra](https://www.jdsupra.com/legalnews/episode-456-buying-a-sanctions-violat-14699) - JD Supra