DOJ Issues New Guidance on Reduced Penalties for Voluntary Disclosure of Export Control and Sanctions Violations
The National Security Division (NSD) of the U.S. Department of Justice (DOJ) recently issued guidance documenting its policy regarding the voluntary self-disclosure (VSD) of potentially criminal violations of the export controls and economic sanctions laws under the Arms Export Control Act and the International Emergency Economic Powers Act.
The guidance provides that qualifying entities will be eligible for:
- non-prosecution agreements
- reduced monetary penalties
- the absence of a corporate monitor
To be eligible for such benefits, however, corporations must comply with the DOJ’s rigorous definitions of:
- voluntary disclosure
- full cooperation
- timely and appropriate remediation
- which include specific requirements regarding the timing and content of the disclosure
- placing the burden for making disclosures of willful violations to the DOJ on the reporting companies
- the identification and production of documents and witnesses from outside the United States
- the implementation of an effective compliance program
To read the entire article: DOJ Issues New Guidance on Reduced Penalties for Voluntary Disclosure of Export Control and Sanctions Violations
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