Unicat Catalyst Technologies Benefits from Self-Disclosure Policy in DOJ Decision
Deal News | Jun 24, 2025 | EIN
The U.S. Department of Justice (DOJ) has decided not to prosecute a U.S. private equity firm after it voluntarily disclosed criminal violations of U.S. sanctions and export control laws committed by its newly acquired company, Unicat Catalyst Technologies LLC (Unicat). This marks the first application of the DOJ's policy on voluntary self-disclosures (VSDs) for mergers and acquisitions (M&A). The DOJ highlighted the private equity firm's decision to self-disclose the misconduct, its full cooperation, and its robust remediation efforts as reasons for declining prosecution. The acquired company, Unicat, entered into a non-prosecution agreement with the DOJ and agreed to pay civil monetary penalties for violating U.S. sanctions and export control laws. Unicat's former CEO pleaded guilty to related offenses. The case underlines the importance of due diligence and self-disclosure in post-acquisition phases to avoid prosecution and financial penalties.
Sectors
- Private Equity
- Export Control and Sanctions Compliance
- Chemical Manufacturing
Geography
- United States – The DOJ, White Deer Management LLC, and Unicat Catalyst Technologies LLC are based in the United States, making it the primary geographic focus.
- Sanctioned Countries – The article involves sales to entities in countries under U.S. sanctions, including Iran, Venezuela, Syria, and Cuba, highlighting these areas in the geopolitical context.
Industry
- Private Equity – White Deer Management LLC, the private equity firm involved, is part of the private equity industry due to its acquisition and investment in Unicat Catalyst Technologies.
- Export Control and Sanctions Compliance – The violations and subsequent legal proceedings are related to export control and sanctions laws, highlighting the industry of legal compliance and enforcement.
- Chemical Manufacturing – Unicat Catalyst Technologies LLC operates within the chemical manufacturing sector, as it was involved in sales of catalysts to businesses in sanctioned countries.
Financials
- US$3.33 million – Revenue generated by Unicat from illegal sales to customers in sanctioned countries from 2014 to 2021.
- US$3,882,797 – Civil monetary fine imposed on Unicat by OFAC for violating U.S. sanctions and export controls.
- US$3,325,052.10 – Amount credited against OFAC's penalty from Unicat's forfeiture money judgment.
Participants
| Name | Role | Type | Description |
|---|---|---|---|
| Unicat Catalyst Technologies LLC | Target Company | Companies | The company acquired by White Deer Management that was involved in violating U.S. export controls and sanctions. |
| White Deer Management LLC | Acquiring Company | Companies | A U.S. private equity firm that acquired Unicat Catalyst Technologies and disclosed the violations to the DOJ. |
| Department of Justice (DOJ) | Government | Government | The U.S. government department that decided not to prosecute White Deer following a voluntary self-disclosure. |
| Office of Foreign Assets Control (OFAC) | Government | Government | The U.S. Department of Treasury office that imposed civil penalties on Unicat for sanctions violations. |
| Bureau of Industry and Security (BIS) | Government | Government | A U.S. Department of Commerce bureau involved in enforcing export control violations, imposing penalties on Unicat. |