News & Analysis as of

Export Controls Voluntary Disclosure

The Volkov Law Group

DOJ Expands Whistleblower Program to Include Tariffs, Sanctions and Export Controls (Part III of III)

The Volkov Law Group on

DOJ’s new Corporate Enforcement Program is designed to bring certainty to the voluntary disclosure and cooperation process.  DOJ’s intent is clear — voluntary disclosure is likely to lead to a declination, reduced penalties...more

Morrison & Foerster LLP

DOJ Issues Declination in Corporate Export Control Violations Matter

On April 30, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced its second-ever public declination under its updated corporate voluntary self-disclosure (VSD) policy when it declined to charge...more

The Volkov Law Group

Voluntary Self-Disclosure Shields Universities Space Research Association from Prosecution by DOJ

The Volkov Law Group on

On April 30, 2025, the U.S. Department of Justice’s National Security Division (“NSD”) issued a formal declination of prosecution to the Universities Space Research Association (“USRA”) following the organization’s timely and...more

Faegre Drinker Biddle & Reath LLP

DOJ National Security Division Issues Second Declination Since Issuance of Revised Corporate Enforcement Policy

On April 30, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) announced the declination of prosecution against the Universities Space Research Association (USRA), a federal government contractor,...more

WilmerHale

Voluntary Disclosure of Export Control Violations is Critical for Settling Criminal Liability, DOJ Action Shows

WilmerHale on

The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...more

Baker Botts L.L.P.

Justice Department Declines Prosecution of U.S. Contractor for Export Control Violations of Rogue Employee

Baker Botts L.L.P. on

For only the second time under its updated voluntary self-disclosure program, the U.S. Justice Department decided not to prosecute Universities Space Research Association after the company self-disclosed criminal violations...more

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

The Volkov Law Group

Córdoba Music Group Settles with OFAC for $41,591 for Violations of Iran Sanctions Program

The Volkov Law Group on

Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

Bracewell LLP

Enforcement Trends 2025: Magic 8 Ball Says "Try Again Later"

Bracewell LLP on

As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

The Volkov Law Group

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws.  Companies have to weigh carefully the risks when...more

Adams & Reese

International Compliance Digest - September 2024

Adams & Reese on

New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Alston & Bird

BIS Powers Up Its Voluntary Self-Disclosure Process and Penalty Guidelines

Alston & Bird on

Our International Trade & Regulatory Group highlights changes to the voluntary self-disclosure process and penalty guidelines under the Export Administration Regulations by the Bureau of Industry and Security....more

Troutman Pepper Locke

BIS Issues Key Updates to the ‎Voluntary Self-Disclosure Process ‎and Penalty Guidelines

Troutman Pepper Locke on

On September 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule that requires reporting entities to make significant changes to Voluntary Self-Disclosures (“VSD”); the BIS...more

Torres Trade Law, PLLC

BIS Tightens Export Control Enforcement

Torres Trade Law, PLLC on

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) just issued a significant rule change that reshapes the landscape of export control enforcement. Published on September 16, 2024, the rule amends the...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU’s 14th Sanctions Package: Compliance Obligations Expand and Exits Are Facilitated

On 24 June 2024, the European Union (EU) adopted its 14th sanctions package directed against Russia, imposing an asset freeze against an additional 116 individuals and entities and expanding sectoral sanctions targeting key...more

Robinson & Cole LLP

Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

Robinson & Cole LLP on

On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

Sheppard Mullin Richter & Hampton LLP

BIS Summer Update: Essential Reading for Your Next Beach Trip!

As we pass the midpoint of a year marked by assertive enforcement of dual use laws, the Department of Commerce’s Bureau of Industry and Security (BIS) published an updated version of its Don’t Let This Happen to You! Guide....more

Akin Gump Strauss Hauer & Feld LLP

DOJ Announces First-Ever Corporate Declination Under National Security Division’s Voluntary Self-Disclosure Program

Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more

McGuireWoods LLP

Disruptive Technology Strike Force Announces Its First Declination to Prosecute Under the National Security Division’s Voluntary...

McGuireWoods LLP on

On May 22, 2024, the Department of Justice’s National Security Division (“NSD”) announced its first declination of prosecution for a company under the voluntary self-disclosure program established by the National Security...more

The Volkov Law Group

DXC Technology Company Settles Sanctions and Export Control Violations

The Volkov Law Group on

On May 17, 2024, Nevada-based DXC Technology Company (“DXC”)—a global IT services provider—officially filed its required annual 10-K Form with the U.S. Securities and Exchange Commission (“SEC”) indicating that...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – April 2024

You are reading the April 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. April saw...more

Torres Trade Law, PLLC

DOJ Involvement in the Enforcement of Trade and National Security Laws

Torres Trade Law, PLLC on

The U.S. agencies most well-known for their enforcement of U.S. trade and national security laws are the Bureau of Industry and Security (“BIS”), the Directorate of Defense Trade Controls (“DDTC”), the Office of Foreign...more

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