News & Analysis as of

Export Administration Regulations (EAR) Voluntary Disclosure Self-Disclosure Requirements

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

Akin Gump Strauss Hauer & Feld LLP

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

Vinson & Elkins LLP

BIS Streamlines Voluntary Self-Disclosure Requirements, But Exporters Should Carefully Evaluate Before Using This Process

Vinson & Elkins LLP on

As many of you are aware, with some minor exceptions, the United States bifurcates export controls responsibility between the Department of State, which administers the International Traffic in Arms Regulations (the “ITAR”),...more

Bracewell LLP

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

Bracewell LLP on

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

Locke Lord LLP

Joint Compliance Note Issued by ‎Departments of Justice, ‎Commerce and Treasury on Voluntary ‎‎Self-Disclosure of ‎Potential...

Locke Lord LLP 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

Foley Hoag LLP

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Regarding Self-Disclosure of Potential Sanctions Violations

Foley Hoag LLP on

On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) 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...more

Hogan Lovells

U.S. agencies signal reinforced export enforcement collaboration and partnership

Hogan Lovells on

The U.S. Departments of Commerce, Justice and Treasury have issued a “Tri-Seal” Compliance Note regarding national security laws and regulations and the voluntary self-disclosure of potential violations, highlighting...more

K&L Gates LLP

US Government to Penalize Failures to Disclose Possible Export Control Violations and Incentivize Reporting of Others' Violations

K&L Gates LLP on

A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing policies that favor such disclosure by...more

A&O Shearman

Commerce Raises Enforcement and Compliance Profile

A&O Shearman on

On April 18, 2023, the U.S. Department of Commerce (“Commerce”)’s Assistant Secretary for Export Enforcement issued a Memorandum titled “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning...more

Venable LLP

New Carrot, New Stick: Commerce Encourages Voluntary Self-Disclosures and Disclosures on Others for Potential Export Control...

Venable LLP on

On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies encouraging both Voluntary Self-Disclosures...more

Morrison & Foerster LLP

Department of Commerce Announces Changes to Voluntary Self-Disclosure Program that Significantly Alter Disclosure Incentives

Continuing the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) efforts to bolster enforcement and compliance, on April 18, 2023, BIS issued a memorandum announcing significant changes to its voluntary...more

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