News & Analysis as of

Export Controls Voluntary Disclosure Department of Justice (DOJ)

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

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

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

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

Robinson & Cole LLP

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

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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

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

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

Hogan Lovells

U.S. Department of Justice updates its Enforcement Policy for Business Organizations

Hogan Lovells on

On March 7, 2024, the U.S. Department of Justice’s National Security Division (NSD) issued an updated Enforcement Policy for Business Organizations. The updated policy encourages companies to voluntarily disclose to NSD...more

Mayer Brown

US DOJ’s National Security Division Updates Enforcement Policy for Criminal Sanctions and Export Control Violations with New Focus...

Mayer Brown on

On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more

Morrison & Foerster LLP

Tri-Seal Compliance Note Stresses Importance of Non-U.S. Persons Complying with U.S. Sanctions and Export Control Laws

On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more

Torres Trade Law, PLLC

U.S. Government to Foreign Persons: Comply with Economic Sanctions and Export Control Laws

In a move that highlights the U.S. government’s ongoing fight against evasion of sanctions and export control laws, the Departments of the Treasury, Commerce, and Justice yesterday published yet another Tri-Seal Compliance...more

Foodman CPAs & Advisors

Nota De Cumplimiento Del BIS, DOJ Y OFAC

Foodman CPAs & Advisors on

El 26/07/2023, el Departamento de Justicia de los EE. UU. (DOJ), la Oficina de Industria y Seguridad del Departamento de Comercio de los EE. UU. (BIS) y la Oficina de Control de Activos Extranjeros (OFAC) del Departamento del...more

Foodman CPAs & Advisors

Compliance Note From BIS, DOJ & OFAC

Foodman CPAs & Advisors on

On 07/26/2023, the U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), issued a...more

WilmerHale

OFSI Encourages Self-Reporting of Sanctions Breaches

WilmerHale on

Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

The Volkov Law Group

Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure

The Volkov Law Group on

In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated prosecutions for sanctions and export control violations.  The last piece in launching this new...more

Husch Blackwell LLP

The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and...

Husch Blackwell LLP on

On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

K2 Integrity on

The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

The Volkov Law Group

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

The Volkov Law Group on

In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations.  The last piece in...more

Troutman Pepper Locke

Joint Compliance Note Issued by ‎Departments of Justice, ‎Commerce and Treasury on Voluntary ‎‎Self-Disclosure of ‎Potential...

Troutman Pepper Locke on

On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a...more

Akin Gump Strauss Hauer & Feld LLP

Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

Akerman LLP on

On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

Ballard Spahr LLP on

On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

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