News & Analysis as of

National Security Voluntary Disclosure Economic Sanctions

Proskauer Rose LLP

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

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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

Hogan Lovells

The NSD declines prosecution for the first time under its M&A Policy

Hogan Lovells on

On June 16, 2025, the U.S. Department of Justice (DOJ) publicly announced that it had declined to prosecute White Deer Management LLC (White Deer) and certain affiliates for violations of sanctions law and related conduct....more

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

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

Bracewell LLP

Enforcement Trends 2025: Magic 8 Ball Says "Try Again Later"

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As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...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

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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

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

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2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Bracewell LLP

DOJ Spotlights Voluntary Self Disclosure in M&A as it Adapts to New National Security Threats

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The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...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

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

Jones Day on

In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....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

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

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

Ballard Spahr LLP on

On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), 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...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

Torres Trade Law, PLLC

Trade Alert: Justice, Commerce, and Treasury Departments Issue a Tri-Seal Compliance Note on Voluntary Self-Disclosures

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On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more

Dorsey & Whitney LLP

Department of Justice Announces First-Ever Pilot Program on Compensation Incentives and Clawbacks, Revisions to Corporate Guidance...

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On March 2, 2023, in remarks delivered at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy creating incentives for companies to adopt...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

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

Foley Hoag LLP

DOJ Issues New Policy Regarding Voluntary Disclosures of Export Controls and Sanctions Violations

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In December, the Department of Justice (DOJ) announced the release of a new policy for business organizations regarding voluntary self-disclosures of export control and sanctions violations. The new Policy makes explicit that...more

WilmerHale

DOJ Revises and Re-Issues Export Control and Sanctions Enforcement Policy for Business Organizations

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On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more

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