The Department of Justice announced it has revised its policy regarding voluntary disclosures of export control and sanctions violations, effective as of Dec. 13.
The Voluntary Self-Disclosure Policy builds on guidance the National Security Division (NSD) issued in October 2016 and will be formally incorporated into the Justice Manual. Companies are encouraged to voluntarily self-disclose all potentially willful violations of the statutes implementing the U.S. government’s primary export control and sanctions regimes—the Arms Export Control Act, the Export Control Reform Act, and the International Emergency Economic Powers Act—directly to the NSD.
