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Export Controls Export Control Reform Act (ECRA) Self-Disclosure Requirements

ArentFox Schiff

BIS Issues Final Rule for Voluntary Self-Disclosure Procedures

ArentFox Schiff on

On Thursday, September 12, 2024, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule updating the agency’s policies on voluntary self-disclosures and the Guidance on Charging and Penalty...more

Snell & Wilmer

Voluntary Self-Disclosures: Update on Federal Agencies’ Efforts to Incentivize Self-Reporting Violations

Snell & Wilmer on

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

King & Spalding

DOJ Releases Updated Export Control and Sanctions Voluntary Disclosure Policy

King & Spalding on

On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more

Stinson - Government Contracting Matters

New Year, New Voluntary Self-Disclosure Policy for Export Controls and Sanctions

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

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