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Exports Self-Disclosure Requirements

The Volkov Law Group

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

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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

Locke Lord LLP

BIS Issues Key Updates to the ‎Voluntary Self-Disclosure Process ‎and Penalty Guidelines

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On September 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule that requires reporting entities to make significant changes to Voluntary Self-Disclosures (“VSD”); the BIS...more

Torres Trade Law, PLLC

BIS Tightens Export Control Enforcement

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The U.S. Department of Commerce's Bureau of Industry and Security (BIS) just issued a significant rule change that reshapes the landscape of export control enforcement. Published on September 16, 2024, the rule amends the...more

Hogan Lovells

U.S. announces export enforcement and compliance resources for academic research institutions

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The U.S. Department of Commerce’s Bureau of Industry and Security has published a compliance note on voluntary self-disclosure trends and a compendium of export compliance resources targeted to the academic community. The...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Hogan Lovells

BIS further enhances voluntary self disclosure process for minor or technical violations

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The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...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

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

Braumiller Law Group, PLLC

[Webinar] ITAR 101 - Part 2 - June 27th, 10:30 am - 11:30 am CST

Join Braumiller Law Group Senior Counsel Bruce Leeds for a discussion on the topic of: ITAR 101-Part 2* New to the International Traffic in Arms Regulations (ITAR)? Or, maybe you're just a little bit rusty on the ITAR? Here...more

K&L Gates LLP

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

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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

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

The Volkov Law Group

BIS Clarifies Approach to Export Enforcement Concerning Voluntary Self Disclosures and Reporting of Third Party Misconduct under...

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On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) released a set of “policy clarifications” in the context of a memorandum authored by the...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

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Ankura

BIS Issues Important Policy Changes on Trade Controls Violations Prevention and Enforcement

Ankura on

Matthew Axelrod, the Assistant Secretary of Commerce for Export Enforcement with the Department of Commerce, recently made two important statements on how the Department will enforce trade controls and address violations....more

Foley Hoag LLP

Department of Commerce’s Bureau of Industry and Security Eyes Enforcement and Voluntary Disclosure Review Policy Changes

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June 23, 2022 Key Takeaways: In two recent speeches, Matthew Axelrod, Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (“BIS”), has signaled policy changes related to...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2022 - Primer on Deemed Export Compliance

When most people think of exports, they imagine the movement of merchandise across international borders. However, an export can happen without having to leave the United States, such as in your office breakroom, by storing...more

Morrison & Foerster LLP

OFAC Penalizes Communications Systems Exporter For Sudan Sales And Related Services

On September 17, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) reached a $894,111 settlement with Comtech Telecommunications Corp. (“Comtech”) and its subsidiary Comtech EF Data Corp. (“EF...more

Snell & Wilmer

No Prosecution, No Fine Presumption for Companies that Voluntarily Self Disclose Potentially Willful Violations of Export and...

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On December 13, 2019, the Department of Justice (DOJ) updated its enforcement guidelines to include a no-fine, no-prosecution presumption for companies that voluntarily self-disclose potentially willful violations of the...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

King & Spalding

DOJ Releases Updated Export Control and Sanctions Voluntary Disclosure Policy

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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

Stinson - Government Contracting Matters

New Year, New Voluntary Self-Disclosure Policy for Export Controls and Sanctions

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

Dechert LLP

DOJ Revised Policy on Voluntary Self-Disclosures of Sanctions and Export Violations

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On December 13, 2019, the U.S. Department of Justice (“DOJ”) issued a new policy for companies that voluntarily disclose potential criminal violations of U.S. sanctions and export control laws to the DOJ’s National Security...more

Cozen O'Connor

DOJ Offers Incentives to Encourage Self-Reporting of Export and Sanctions Violations

Cozen O'Connor on

The National Security Division of the U.S. Department of Justice (DOJ) has revised its guidance regarding Voluntary Self-Disclosures (VSD), originally published in October 2016, to further encourage companies to self-report...more

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