DOJ releases updated export control and sanctions enforcement policy for business organizations

On 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanction Enforcement Policy for Business Organizations (the Enforcement Policy). The Enforcement Policy sets forth the criteria to be used by DOJ – through NSD's Counterintelligence and Export Control Section (CES), in partnership with U.S. Attorney's Offices nationwide – to determine "an appropriate resolution" for an organization that makes a voluntary self-disclosure (VSD), directly to NSD, for "potentially willful violations" of United States export control and sanctions law. The Enforcement Policy reflects a clear effort by NSD to increase its cooperation with the private sector by providing more clearly defined benefits for companies that make voluntary selfdisclosures and by more closely aligning the NSD guidance with recent guidance issued throughout DOJ.

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