United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more
Our International Trade & Regulatory and White Collar, Government & Internal Investigations Groups review the Justice Department’s revised voluntary self-disclosure policy and find that it is a welcome change for companies...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more