By Michael Diaz, Jr.; Javier Coronado; Isabela Hernández-Pereda; Gábor Gazsó von Klingspor and John Foster.
1 Identify the highest-profile corporate investigation under way in your country, describing and commenting on its most noteworthy aspects.
The most prominent ongoing corporate enforcement actions in the United States are the national security investigations arising from the June 2025 global resolution involving Unicat Catalyst Technologies, LLC, its former CEO and private equity owner White Deer Management LLC. Coordinated among the US Department of Justice (DOJ), the Treasury Department’s Office of Foreign Assets Control (OFAC), the Commerce Department’s Bureau of Industry and Security and US Customs and Border Protection (CBP), the matter resulted in White Deer receiving a declination after voluntarily self-disclosing misconduct discovered post-acquisition. However, the DOJ pursued a non-prosecution agreement (NPA) with Unicat and secured a guilty plea from the former CEO. The combined monetary penalties and forfeitures exceed US$9 million, covering sanctions violations involving Iran, Venezuela, Syria and Cuba; export control breaches; and underpayment of customs duties.
The Venezuelan component is among the most consequential aspects of this case. According to the US government, Unicat supplied catalyst products to Orinoco Iron SCS, which was owned at the time by the sanctioned government of Venezuela. The products were sourced and shipped from China, through both Unicat’s affiliate and third parties. OFAC deemed these actions egregious, citing senior management involvement, wilfulness and the provision of essential technology to core sectors of Venezuela’s sanctioned industries. On the same day the Unicat resolutions were announced, the DOJ also revealed the arrests of a Venezuelan national and a US citizen on charges of conspiring to supply millions of dollars’ worth of catalysts, industrial equipment and related services to Complejo Siderúrgico de Guayana SA, a Venezuelan state-owned steel company subject to US sanctions.
