DOJ Issues Revised Export Control and Sanctions Enforcement Policy for Business Organizations Providing Clear Guidance on the Benefits of Self-Disclosing Violations -

On December 13, 2019, the Department of Justice (DOJ) released a new policy on voluntary self-disclosures of export control and sanctions violations (the “New VSD Policy”). In contrast to the guidance released in October 2016 regarding voluntary self-disclosures in export controls and sanctions investigations (the “2016 Guidance”), the New VSD Policy applies to all organizations, including financial institutions.