Companies seeking credit for voluntarily self-disclosing potential violations of sanctions or export control laws must be mindful of the multiple regimes at play and their differing expectations.
A compliance note released by the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), and Treasury Department’s Office of Foreign Assets Control (OFAC) on Wednesday explains how each agency assesses voluntary self-disclosure when determining whether reporting companies qualify for potential reductions in penalties. The guidance follows policy updates by the DOJ and BIS in recent months designed to incentivize self-reporting before the government initiates an investigation.
