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New U.S. DOJ voluntary self-disclosure policy

On 13th December 2019, the U.S. Department of Justice (DOJ) announced a revised policy for business organizations voluntarily disclosing export control and sanctions violations. The Voluntary Self-Disclosure Policy, or VSD Policy, encourages companies to voluntarily self-disclose potential violations of main U.S. export control and sanction regimes, namely, the Arms Export Control Act (AECA), 22 U.S.C. § 2778, the Export Control Reform Act (ECRA), 50 U.S.C. § 4801 et seq., and the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. § 1705. The three main changes in the VSD Policy, in comparison to proceeding regulations, are:

  1. companies that voluntarily disclose a potential violation, cooperate, and remediate appropriately, will receive a non-prosecution agreement and will not be fined, barring aggravating factors.

  2. the voluntary self-disclosure must be made directly to the National Security Division (NSD) of the Department of Justice.

  3. definitions of key terms have been revised to “more closely resemble existing and analogous guidance from other DOJ components.”

Please follow this link to read the new VSD Policy.

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