Although the change in presidential administration has unquestionably brought with it a shift in enforcement priorities, pursuing trade- and sanctions-related violations is one area of continuity. For example, in 2022, former Deputy Attorney General Lisa Monaco called sanctions enforcement the “new [Foreign Corrupt Practices Act],” while, this spring, Commerce Secretary Howard Lutnick signaled “a dramatic increase” in export controls enforcement. Meanwhile, DOJ officials have explicitly prioritized investigation of “trade and customs” violations. Signaling greater scrutiny of non-bank financial institutions, the DOJ’s Criminal Division has promised to focus on “conduct that threatens the country’s national security, including threats to the U.S. financial system by gatekeepers.” And it has noted that “[f]inancial institutions, shadow bankers, and other intermediaries aid U.S. adversaries by processing transactions that evade sanctions.” Two recent enforcement actions highlight those priorities, as well as the government’s increasing focus on non-bank financial institutions as financial “gatekeepers.” These actions illustrate that, more than ever, the government stands ready to impose penalties on investment fund managers that engage in criminal and regulatory violations, viewing them as responsible for the downstream effects of their investments and the conduct of their portfolio companies. But government agencies have simultaneously amplified the benefit of cooperation and voluntary self-reporting. This guest article by MoloLamken attorneys Eric R. Nitz, Anden Chow and Walter H Hawes IV discusses the two actions and the differing fates of the firms involved, highlighting the government’s dual-track approach. For more insights from Nitz, see “Agency Power and Adjudication: The Government Seeks Supreme Court Review of Jarkesy v. SEC” (Jun. 8, 2023).