Compliance and legal teams whose companies are internally investigating possible sanctions and export controls violations will have to work a lot harder to get credit with federal officials for making a voluntary self-disclosure, thanks to a new guidance document from the Department of Justice.
The rationale for proceeding with greater caution emanates from guidance issued last month by the National Security Division (NSD) of the Department of Justice. Established by Congress in 2006, the NSD is responsible for protecting the United States from national security threats and achieves this by uniting prosecutors and law enforcement officials with the intelligence community.
