News & Analysis as of

Department of Justice (DOJ) Bureau of Industry and Security (BIS) Voluntary Disclosure

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

Proskauer Rose LLP on

On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...more

The Volkov Law Group

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

The Volkov Law Group on

DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

The Volkov Law Group on

In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

White & Case LLP on

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...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

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

Adams & Reese

International Compliance Digest – August 2024

Adams & Reese on

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

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

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

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

King & Spalding on

Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...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

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

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

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