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
On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations,...more