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Exports Voluntary Disclosure

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

Hogan Lovells

U.S. announces export enforcement and compliance resources for academic research institutions

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The U.S. Department of Commerce’s Bureau of Industry and Security has published a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources targeted to the academic community. The...more

Torres Trade Law, PLLC

DOJ Involvement in the Enforcement of Trade and National Security Laws

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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

Goodwin

Bigger Fish to Fry: BIS Refines Voluntary Self-Disclosure Process for Minor EAR Violations

Goodwin on

The US Department of Commerce’s Bureau of Industry and Security (BIS), which administers the Export Administration Regulations (EAR) and regulates most exports from the United States, announced further updates to the process...more

Pillsbury - Global Trade & Sanctions Law

BIS Issues Additional Enhancements to Voluntary Self-Disclosure Process

Takeaways: On January 16, 2024, the Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) announced several updates to its Voluntary Self-Disclosure (VSD) process aimed at enhancing the program’s...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - February 2024 - BIS Unveils Enhanced Voluntary Self Disclosure Protocols

On January 16, 2024, the Bureau of Industry and Security (BIS) under Assistant Secretary for Export Enforcement, Matthew Axelrod, disclosed significant enhancements to the process for Voluntary Self-Disclosures (VSDs) related...more

Hogan Lovells

BIS further enhances voluntary self disclosure process for minor or technical violations

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The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more

Akin Gump Strauss Hauer & Feld LLP

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

Torres Trade Law, PLLC

Understanding ITAR Mandatory Disclosures and the “Duty to Inform” DDTC

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The discovery of actual or potential International Traffic in Arms Regulations (“ITAR”) violations presents the question of whether to disclose the conduct to the Department of State Directorate of Defense Trade Controls...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

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Bass, Berry & Sims PLC

Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury

On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more

Braumiller Law Group, PLLC

[Webinar] ITAR 101 - Part 2 - June 27th, 10:30 am - 11:30 am CST

Join Braumiller Law Group Senior Counsel Bruce Leeds for a discussion on the topic of: ITAR 101-Part 2* New to the International Traffic in Arms Regulations (ITAR)? Or, maybe you're just a little bit rusty on the ITAR? Here...more

Womble Bond Dickinson

U.S. Commerce Department Incentivizes Disclosures of Export Control Violations

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) continues to send a strong and clear message to the exporting community – it wants businesses and universities to voluntarily disclose any significant...more

K&L Gates LLP

US Government to Penalize Failures to Disclose Possible Export Control Violations and Incentivize Reporting of Others' Violations

K&L Gates LLP on

A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing policies that favor such disclosure by...more

Venable LLP

New Carrot, New Stick: Commerce Encourages Voluntary Self-Disclosures and Disclosures on Others for Potential Export Control...

Venable LLP on

On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more

Morrison & Foerster LLP

Department of Commerce Announces Changes to Voluntary Self-Disclosure Program that Significantly Alter Disclosure Incentives

Continuing the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) efforts to bolster enforcement and compliance, on April 18, 2023, BIS issued a memorandum announcing significant changes to its voluntary...more

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

Torres Trade Law, PLLC

Torres Talks Trade Podcast- Episode 13- When Government Agencies Come Knocking

Torres Trade Law, PLLC on

In the second of a two-part series on the BIS Office of Export Enforcement, host Olga Torres sits down with former BIS Special Agents Don Pearce and Jim Fuller to discuss what to do when government enforcement agencies come...more

Torres Trade Law, PLLC

Torres Talks Trade Episode 11 on Sanctions and Export Enforcement Cases by DOJ

In this episode, host Olga Torres is joined by David Laufman, former Chief of the Counterintelligence and Export Controls Section, “CES,” at the Department of Justice to discuss high-profile sanctions and export enforcement...more

Procopio, Cory, Hargreaves & Savitch LLP

Why Voluntary Self-Disclosure of National Security-Related Transgressions is Critical for Defense-Related Businesses

Regulatory compliance is critical for any business involved in the export of defense related commodities. Violations under the International Traffic in Arms Regulation (ITAR) or the Export Administration Regulations (EAR) can...more

Morrison & Foerster LLP

DOJ Announces Resolution Of First-Ever Voluntary Self-Disclosure Related To Export Control And Sanctions Violations

On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “DOJ”) announced that DOJ entered into a precedent-setting...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

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On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Vinson & Elkins LLP

Berkshire Hathaway’s $4.1 Million OFAC Settlement Underscores Risks Of Subsidiaries’ Compliance Failures And Benefits Of Voluntary...

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On October 20, 2020, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had reached a $4.1 million settlement with Berkshire Hathaway, Inc., the multinational conglomerate holding company...more

Snell & Wilmer

No Prosecution, No Fine Presumption for Companies that Voluntarily Self Disclose Potentially Willful Violations of Export and...

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On December 13, 2019, the Department of Justice (DOJ) updated its enforcement guidelines to include a no-fine, no-prosecution presumption for companies that voluntarily self-disclose potentially willful violations of the...more

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