News & Analysis as of

Compliance Voluntary Disclosure U.S. Commerce Department

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
The Volkov Law Group

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

The Volkov Law Group on

The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws.  Companies have to weigh carefully the risks when...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

Morrison & Foerster LLP

Tri-Seal Compliance Note Stresses Importance of Non-U.S. Persons Complying with U.S. Sanctions and Export Control Laws

On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more

WilmerHale

OFSI Encourages Self-Reporting of Sanctions Breaches

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Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...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

Torres Trade Law, PLLC on

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

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (June 21, 2023)

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Recent developments include fair warning from the Department of Justice that national security concerns can invade even ordinary business activities, a reminder that the False Claims Act increasingly is being used as a weapon...more

Kramer Levin Naftalis & Frankel LLP

Commerce Department to Penalize Failure to Voluntarily Self-Disclose Significant Export Violations

In concert with the Department of Justice’s (DOJ) focus on voluntary self-disclosure of corporate misconduct, as well as DOJ’s commitment to addressing sanctions evasion, export control violations and similar economic crimes,...more

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

A&O Shearman

DOJ Offers Non-Prosecution Agreements And No-Fines For Self-Reporting Export Control And Sanctions Violations

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In a development that could significantly affect how companies deal with possible export control and sanctions violations, the Department of Justice (“DOJ”) recently revised its policy regarding voluntary disclosure of trade...more

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