The US Department of Justice has declined to prosecute White Deer Management after the Houston-based private equity firm voluntarily disclosed criminal violations by its portfolio company, Unicat Catalyst Technologies, marking the first use of DOJ’s latest Mergers and Acquisitions Safe Harbor policy.

White Deer acquired Unicat in September 2020. In June 2021, Unicat’s new leadership discovered a pending sale to an Iranian customer, immediately cancelled the deal and retained outside counsel.

Within one month, White Deer and Unicat submitted a voluntary self-disclosure to DOJ’s National Security Division (NSD), Office of Foreign Assets Control (OFAC), and the Commerce Department’s Bureau of Industry and Security (BIS).

Subsequent DOJ investigations found that under former CEO Mani Erfan, Unicat made 23 illegal sales of chemical catalysts to Iran, Syria, Venezuela, and Cuba, bringing in around $3.33 million in revenue. Erfan had also directed employees to falsify export documents and invoices to evade tariffs, avoiding another $1.66 million in duties that should have been paid.

He has pleaded guilty to conspiracy to violate sanctions and money laundering charges, alongside another former Unicat executive who was prosecuted separately.

Under NSD’s Voluntary Self-Disclosures in Connection with Acquisitions Policy, rolled out in March 2024, acquirors that complete a bona fide acquisition, make a timely self-disclosure of national-security-related misconduct, unreservedly cooperate, and remediate are generally presumed not to face prosecution.

According to the declination letter, DOJ considered White Deer’s disclosure timely despite occurring ten months after closing, citing COVID-19 delays, a two-stage merger strategy, and immediate cancellation of the Iran transaction.

DOJ credited White Deer’s “exceptional and proactive” cooperation, which included an extensive self-investigation: the firm voluntarily flagged archived communications on personal devices, internal chat messages, and various foreign-located documents.

Within one year of discovery, Unicat had fired multiple employees, disciplined others, and revamped its compliance function.

While White Deer was not prosecuted, the sponsor still took a financial hit. Voluntary disclosure may help avoid criminal penalties, but does not prevent civil liability.

Unicat entered a non-prosecution agreement and forfeited the $3.3 million in illicit revenue, and agreed to $4.3 million in combined OFAC and BIS settlements (with the DOJ forfeiture credited against the OFAC fine). Unicat also paid $1.7 million in restitution to Customs and Border Protection.

A McDermott, Will & Emery brief warns that this year's US trade policy changes mean sponsors now face greater risk of possible trade-related violations.

In instances of wrongdoing, it can also be easy for problems to quickly cascade into a host of related tax, customs, anti-money laundering, or fraud concerns—broadening the scope of post-acquisition risk.

Buyers who insist on strong seller reps and warranties around trade and sanctions compliance can reduce some exposure, or at least secure a possible claim. Indemnities or escrow holdbacks tied to regulatory violations discovered post-closing can also help.

Neither can prevent regulatory actions, but they can offset potential fines or penalties.

• DuPont (NYSE: DD) is exploring the sale of its protective equipment business, including body armor brand Kevlar, with Advent International and Platinum Equity emerging as the most likely buyers in a deal that could fetch around $2 billion, per the FT.

• Blackstone is acquiring the remaining minority stake in Cvent, an events software platform, from Vista Equity Partners for $1.3 billion.

• Packaging Corp. of America (NYSE: PKG) agreed to acquire Greif's (NYSE: GEF) containerboard business, including mills in Ohio and Virginia, for $1.8 billion.

• TransDigm (NYSE: TDG) agreed to acquire Simmonds Precision Products, a Vermont-based provider of aerospace and defense sensing solutions, from RTX (NYSE: RTX) for $765 million.

• Home Depot (NYSE: HD) agreed to acquire GMS (NYSE: GMS), a Georgia-based building products distributor, for $5.5 billion, outbidding an unsolicited $5 billion offer from QXO.

• Hyatt Hotels (NYSE: H) agreed to sell its Playa portfolio of 15 all-inclusive resorts across Mexico, the Dominican Republic, and Jamaica for $2 billion to Tortuga Resorts, a joint venture between KSL Capital Partners and Rodina.

• Warburg Pincus is in advanced talks to acquire Uvex, a German ski helmet manufacturer, in a deal that could value the company at around €800 million, per Bloomberg.

• Truelink Capital acquired Zep, an Atlanta-based manufacturer of maintenance and cleaning solutions, from New Mountain Capital.

• Stone Point Capital acquired The Difference Card, a New York-based healthcare cost containment solutions provider, from Northlane Capital Partners.

• Monetate, a New York-based e-commerce personalization platform owned by Centre Lane Partners and GarMark Partners, acquired SiteSpect, a Newton-based A/B testing provider backed by Boathouse Capital, Multiplier Capital, and NewSpring Capital.

• Harvest Partners acquired a majority stake in The Learning Experience, a Deerfield Beach-based franchisor and operator of early childhood education centers, from Golden Gate Capital.

• A consortium led by Mikael Schiller, Caspar Callerström, and Thomas von Koch acquired Swedish luxury menswear brand Eton from EQT.

• CenterOak Partners acquired a majority stake in NOW CFO, a Salt Lake City-based provider of outsourced finance and accounting services.

• Advent International agreed to acquire a majority stake in LayerZero Power Systems, an Ohio-based manufacturer of power distribution equipment for data centers.

• NielsenIQ, a Chicago-based consumer research firm backed by Advent International and KKR, filed for an IPO that could raise around $1 billion.

• Clio, a Canadian legal practice management software provider, agreed to acquire vLex, a Spanish legal-tech platform, from Oakley Capital for $1 billion.

• Porsche is weighing a sale of its IT services and consulting unit MHP, which specializes in digital transformation and automotive software and could be valued at more than €1 billion, per Reuters.

• KKR agreed to sell its 46.4 percent stake in Indian drugmaker JB Pharma to Torrent Pharmaceuticals for $1.4 billion.

• GE Vernova (NYSE: GEV) is weighing a sale of industrial software unit Proficy, which could fetch up to $1 billion, per Bloomberg.

• Thoma Bravo is in talks to acquire Verint Systems (Nasdaq: VRNT), a New York-based customer experience software maker with a $1.1 billion market cap, per Bloomberg.

• SGS (Swiss: SGSN) agreed to acquire Applied Technical Services (ATS), a Marietta, Georgia-based provider of testing, inspection, calibration, and forensics solutions, from Odyssey Investment Partners for $1.3 billion.

• Triton agreed to acquire Prenax, a global subscription management solutions provider operating across 11 countries with over 340,000 subscriptions under management, from LBO France.

• Onto Innovation (NYSE: ONTO), a Wilmington-based chipmaking software company, agreed to acquire Semilab International's material analysis business for $545 million in cash and stock.

• Atlas Holdings agreed to acquire Evraz North America, a specialty steel producer for railway, energy, and infrastructure sectors in the US and Canada, for up to $500 million from U.K. steelmaker Evraz, which is backed by sanctioned Russian oligarch Roman Abramovich.

• AbbVie (NYSE: ABBV) agreed to acquire Capstan Therapeutics, a developer of lipid nanoparticle technology for cell engineering, for up to $2.1 billion.

• EQT has hired UBS to explore the sale of a significant minority stake in the Italian unit of digital infrastructure firm Radius, per Bloomberg.

• Sheridan Capital hired Houlihan Lokey to sell Tarrytown Expocare, an Austin-based specialty pharmacy focused on individuals with intellectual and developmental disabilities, per Axios Pro.

• Brainlab, a German maker of surgical imaging and guidance software backed by EMH Capital, is delaying its domestic IPO.

• McGraw Hill, a Platinum Equity-owned educational publisher, filed for a NYSE IPO that could raise up to $1 billion.

• Accelerant Holdings, an Eldridge Industries-backed specialty insurance marketplace, filed for a $100 million NYSE IPO under the ticker "ARX".

• Delta Utilities, a portfolio company of Bernhard Capital Partners, acquired two regulated natural gas utilities in Louisiana from Entergy (NYSE: ETR).

• Symplr, a portfolio company of Clearlake Capital and Charlesbank, acquired healthcare scheduling software provider Smart Square from AMN Healthcare (NYSE: AMN) for $75 million.

• LAZ Parking, backed by Argo Infrastructure Investors, acquired a 60% stake in Indigo Park Canada.

• Pact Capital Partners acquired a passive minority stake in Graham Partners, a private equity firm focused on manufacturing and tech-enabled services.

• Secur-Serv, a portfolio company of Transom Capital Group, acquired Arrowhead Technologies, a Fort Worth-based managed IT services provider.

• VTIG, an outsourced IT firm owned by The Riverside Co., acquired The Instillery, a New Zealand-based cloud and cybersecurity company.

• Charger Investment Partners acquired Versa-Drill, an Indianapolis-based manufacturer of drilling rigs.

• Foundation Investment Partners acquired AAA Industrial Supply, a Garrett, Indiana-based distributor of industrial supplies and safety equipment, which will be merged with its portfolio company Spartan Tool Supply.

Tech, Vertical SaaS, & Misc. Enterprise

• Cato Networks, a platform unifying enterprise security and networking as a single service, raised $359 million in Series G funding co-led by Vitruvian Partners and ION Crossover Partners, with participation from Lightspeed Venture Partners, Acrew Capital, and Adams Street Partners, at a valuation of $4.8 billion.

• Talon.One, a Berlin-based loyalty and promotion software provider, raised $135 million in growth funding from Silversmith Capital Partners and Meritech Capital, with participation from existing investor CRV.

• Levelpath, an AI-native procurement platform, raised $55 million in Series B funding led by Battery Ventures, with participation from Redpoint Ventures, Benchmark, 01A, New View Capital, and World Innovation Lab.

• HIVED, an AI-powered e-commerce delivery service, raised $42 million in Series B funding led by NordicNinja, with participation from Wex Venture Capital, Marunouchi Innovation Partners, Elemental Impact, Yamato Holdings, Future Back Ventures, Rocketship VC, and Planet A.

• Campfire, an ERP software provider, raised $35 million in Series A funding led by Accel, with participation from Foundation Capital, Y Combinator, and Capital 49.

• Wonderful, an Israeli developer of multilingual AI customer service agents, raised $34 million in seed funding led by Index Ventures, with participation from Bessemer Venture Partners and Vine Ventures.

• Ambrook, a New York-based farm accounting software platform, raised $26.1 million in Series A funding co-led by Thrive Capital and Field Ventures, with participation from Homebrew, BoxGroup, Designer Fund, Mischief, and Not Boring.

• QEDMA, an Israeli quantum computing software company focused on noise resilience, raised $26 million in Series A funding led by Glilot Capital Partners through its early growth fund Glilot+, with participation from IBM, Korean Investment Partners, and TPY Capital.

• Emerald AI, software that optimizes AI workloads to reduce data center power consumption, raised $24.5 million in seed funding led by Radical Ventures, with participation from NVentures, AMPLO, CRV, and Neotribe.

• Tailor, a headless ERP platform for retailers and e-commerce, raised $22 million in Series A funding led by ANRI, with participation from JIC Venture Growth Investments, New Enterprise Associates, Spiral Capital, and Y Combinator.

• Remark, an AI-powered e-commerce platform trained with human expert input, raised $16 million in Series A funding led by Inspired Capital, with participation from Stripe, Neo, Spero Ventures, Shine Capital, and Visible Ventures.

• CRED, a predictive intelligence platform connecting business systems with market signals, raised $15 million in seed funding led by defy.vc, with participation from HOF Capital, Alumni Ventures, LDV Partners, Streamlined Ventures, SilverCircle Ventures, Octopus Ventures, BAM Ventures, and Gaingels.

• Deeto, an AI platform that converts customer feedback into marketing assets, raised $12.5 million in Series A funding led by Jump Capital, with participation from UpWest, TAL Ventures, Mertor, and TAU Ventures.

• Audos, a New York-based platform for building AI businesses, raised $11.5 million in combined Pre-Seed and Seed funding led by True Ventures, with participation from Offline Ventures and Bungalow Capital.

• Bonx, a Paris-based ERP platform for mid-sized manufacturers, raised $8.6 million in seed funding led by 9900 Capital, with participation from Kima Ventures, Purple, OSS Ventures, and Dynamo Ventures.

• KERYS Software, a French IT infrastructure virtualization company, raised €6.2 million in pre-seed funding from Daphni, Seedcamp, and Backtrace, with participation from Kima Ventures.

• TopK, a Czech enterprise search engine that combines vector search, keyword matching, and filtering, raised $5.5 million in seed funding from Earlybird, KAYA, and Irregular Expressions.

• Aircon, an air cargo technology platform for freight forwarders, raised $5 million in seed funding co-led by Blumberg Capital and Las Olas VC, bringing total funding to $8 million.

Fintech

• Klar, a Mexican digital banking platform, raised $190 million in Series C funding at a valuation exceeding $800 million led by General Atlantic, with participation from Prosus, IFC, Mouro Capital, Quona Capital, Santander Group, Grupo Televisa, and Grupo Formula.

• Bilt Rewards, a loyalty platform for earning rewards on rent payments, raised $150 million in new funding led by Teachers' Venture Growth, with participation from Vanderbilt University Endowment and University of Illinois Foundation.

• Savvy Wealth, a platform modernizing financial advisory services, raised $72 million in Series B funding led by Industry Ventures, with participation from Vestigo Ventures, Euclidean Capital, Canvas Ventures, Thrive Capital, The House Fund, and Brewer Lane Ventures.

• Yaspa, a London-based fintech for instant payment and identity services, raised $12 million in Series A funding led by Discerning Capital, with participation from Metavallon and TechStars Ventures.

• Zango, an AI platform that automates regulatory compliance workflows for financial institutions, raised $4.8 million in seed funding led by Nexus Venture Partners, with participation from South Park Commons, Notion Capital, No Label Ventures, and Start Ventures.

Healthcare

• Field Medical, a developer of pulsed field ablation technology for treating cardiac arrhythmias, raised $35 million in Series B funding co-led by BioStar Capital and Cue Growth, with participation from existing strategic investors.

• Portal Biotech, a London-based single-molecule protein sequencing technology company, raised $35 million in Series A funding co-led by NATO Innovation Fund and Earlybird Venture Capital, with participation from SCVC, Pillar VC, 8VC, Amino Collective, Outsized, We Venture Capital, British Business Bank, and WS Investment Company.

• Syntis Bio, a Boston-based biotech developing oral therapies for obesity, diabetes and rare diseases, raised $33 million in Series A funding led by Cerberus Ventures, with participation from Mansueto Investments, Woori Venture Partners, Apollo Labs, BOLD Capital Partners, W.R. Berkley Corporation, Safar Partners, Portal Innovations, Colorcon Ventures, and Cerity Partners Ventures.

• Gallant, an animal health biotech company developing stem cell therapies for pets, raised $18 million in Series B funding led by Digitalis Ventures, with participation from NovaQuest Capital Management, BOLD Capital, and Hill Creek Partners.

• Circulate Health, a Seattle-based company developing plasma exchange technology to reduce biological aging, raised $12 million in seed funding led by Khosla Ventures, with participation from Seaside Ventures and CSC Ventures.

• Argon AI, an AI-native workspace for life sciences teams, raised $5.5 million in seed funding co-led by Crosslink Capital and Wireframe Ventures, with participation from Y Combinator and Pioneer Fund.

• LogicFlo AI, a Boston-based AI platform for life sciences, raised $2.7 million in seed funding led by Lightspeed, with participation from healthcare and enterprise AI investors.

Industrials, Greentech, & Other

• Climeworks, a Swiss direct air capture technology company, raised $162 million in Series D funding co-led by BigPoint Holding and Partners Group, with participation from existing investors.

• Genesis AI, a robotics company developing foundational models for general-purpose robots, raised $105 million in seed funding co-led by Eclipse Ventures and Khosla Ventures, with participation from Bpifrance and HSG.

• Terrana Biosciences, a developer of RNA-based agricultural solutions, raised $50 million in Series A funding from Flagship Pioneering.

• Skynopy, a French ground station services provider for low Earth orbit satellites, raised €15 million in Series A funding led by Alven, with participation from Expansion, Omnes, CNES via the SpaceFounders program, and Heartcore Capital.

• Civ Robotics, a company developing autonomous surveying robots for construction sites, raised $7.5 million in Series A funding led by AlleyCorp, with participation from Bobcat Company, ff Venture Capital, and existing investors.

• Vok Bikes, an Estonian company making four-wheeled electric cargo bikes for urban logistics, raised $6 million in Series A funding led by SQM Lithium Ventures, with participation from Metaplanet, Specialist VC, Sunly, and SmartCap.

• Tibo Energy, a Dutch developer of energy management systems for industrial and commercial sites, raised €6 million in seed funding led by KOMPAS VC, with participation from Hitachi Ventures, WEPA Ventures, SET Ventures, and Speedinvest.

• Commonwealth Fusion Systems, a fusion energy company developing commercial power plants, raised an undisclosed amount in Series C funding from Google, which also signed a 200-megawatt power purchase agreement for electricity from CFS's inaugural ARC power plant in Virginia expected to come online in the early 2030s.

• Recognize raised $1.7 billion for its second digital services-focused fund.

• Shore Capital Partners raised over $450 million for its third lower middle market food and beverage fund.

• Growth Capital Partners raised £411 million for its sixth fund.

• Catalio raised $400 million for its fourth biotech venture capital fund.

• Omnes Capital raised €112 million at first close for its second European deeptech fund, focusing on defense, AI, quantum technology, and new space sectors.

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