News & Analysis as of

Voluntary Disclosure Export Controls Penalties

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

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

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

Dechert LLP

BIS Enhances Its Voluntary Self-Disclosure Process and Related Enforcement Guidance

Dechert LLP on

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (the “Rule”) regarding changes to the provisions of the Export Administration Regulations (the “EAR”) governing voluntary...more

Torres Trade Law, PLLC

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

Torres Trade Law, PLLC on

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

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

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

Venable LLP

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

Venable LLP on

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

McCarter & English, LLP

Apocalypse Soon? Permanent Disqualification From Department of Defense Contracts May Result From Voluntary Disclosures of Export...

McCarter & English, LLP on

Etymology, particularly the Greek or Latin roots of words, aids our understanding in much the same way as root cause analysis does. The Greek word for disclosure is αποκάλυψη, transliterated to apokálypsi, or “apocalypse.”...more

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