Cross-Border Compliance Update: December 2019

Foley Hoag LLP

DOJ Issues Revised Export Control and Sanctions Enforcement Policy for Business Organizations Providing Clear Guidance on the Benefits of Self-Disclosing Violations -

On December 13, 2019, the Department of Justice (DOJ) released a new policy on voluntary self-disclosures of export control and sanctions violations (the “New VSD Policy”). In contrast to the guidance released in October 2016 regarding voluntary self-disclosures in export controls and sanctions investigations (the “2016 Guidance”), the New VSD Policy applies to all organizations, including financial institutions.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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