News & Analysis as of

Corporate Counsel National Security Voluntary Disclosure

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...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

Wilson Sonsini Goodrich & Rosati

National Security Division’s Voluntary Self-Disclosure Policy in Action: Exchanging Cooperation for Declination

Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...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

Morrison & Foerster LLP

DOJ National Security Division Issues First-Ever Declination Under Voluntary Self-Disclosure Policy

On May 22, 2024, the Department of Justice’s (DOJ) National Security Division (NSD) announced its first-ever prosecution declination under its corporate voluntary self-disclosure (VSD) policy for sanctions and export controls...more

Sheppard Mullin Richter & Hampton LLP

A Look into DOJ’s Current Corporate Criminal Enforcement Landscape

At the Global Investigations Review Annual Meeting in New York on September 21, 2023, Principal Associate Deputy Attorney General Marshall Miller (“Miller”) delivered remarks that provide an invaluable glimpse into the...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

Fenwick & West LLP on

On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

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