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Department of Justice Revises Policy Regarding Voluntary Disclosures of Export Control and Sanctions Violations

The revised policy both clarifies and expands DOJ’s prior disclosure guidance. On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more

DOJ Announces Continuation and Ongoing Review of FCPA Pilot Program

The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives. The Department of Justice (DOJ) recently announced...more

US Department of Justice Guidance Seeks to Encourage Voluntary Self-Disclosure of Export Controls and Sanctions Violations

The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives. The National Security Division (NSD) of the US Department of Justice (DOJ)...more

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