Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 10 JULY 2026

DOJ Issues First Corporate Enforcement Policy Declination: Lessons From Bosch’s FDPR Export Control Resolution

Bass, Berry & Sims PLC
Explore more from Bass, Berry & Sims PLC

DOJ’s Corporate Enforcement Policy (CEP) provides a concrete path to avoid criminal prosecution for export control violations when companies voluntarily self-disclose, fully cooperate, and implement meaningful...

GlobalInternational Law
Faith Dibble
Faith Dibble
Thaddeus R. McBride
Thaddeus R. McBride

Key Takeaways

  • DOJ’s Corporate Enforcement Policy (CEP) provides a concrete path to avoid criminal prosecution for export control violations when companies voluntarily self-disclose, fully cooperate, and implement meaningful remediation.
  • Early disclosure is critical. Bosch reported potential FDPR violations to DOJ while its internal investigation was still ongoing, which DOJ specifically highlighted as a factor supporting the declination.
  • A declination does not eliminate financial consequences. Bosch will pay approximately $40 million in combined civil penalties and disgorgement, demonstrating that self-disclosure reduces criminal risk but does not guarantee full immunity from enforcement costs.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

Trump Administration Waives New Russia Sanctions And Tariffs Under Graham Act

President Trump issued an executive order implementing the Graham Act, which establishes substantial new tariffs on Russian goods and countries purchasing Russian energy, but simultaneously waives their application. The order creates a monitoring framework that leaves open the possibility of future enforcement while maintaining existing Russia sanctions regimes.
GlobalInternational Law
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Article

FCC Replaces TCPA “Revoke All” Rule: New Category-Specific Opt-Out Rules For Robocalls And Robotexts

The Federal Communications Commission has fundamentally altered how businesses must handle consumer opt-out requests under the Telephone Consumer Protection Act, replacing the broad "revoke all" mandate with a more nuanced, category-specific approach for informational messages. This regulatory shift allows companies to maintain separate consent tracks for different types of non-marketing communications while preserving stricter opt-out requirements for telemarketing messages. The Updated Order introduces ne
United StatesConsumer Protection
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

Tennessee 2026 Midterm Election Results: Blackburn Wins Governor’s Race Amid Congressional And Legislative Upsets

Tennessee's 2026 midterm elections brought unexpected shifts to the state's political landscape, with Marsha Blackburn winning the governorship by the narrowest margin in over a century and Democrats flipping six House seats despite Republican supermajority retention. The results set the stage for significant leadership changes and new policy priorities when the 115th General Assembly convenes in January 2027.
United StatesGovernment, Public Sector
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

Healthcare Trends & Transactions Q2 2026

Healthcare M&A activity maintained steady momentum through Q2 2026, driven by physician practice consolidation, AI-enabled technology acquisitions, and strategic outpatient expansion. Private equity investment persisted despite intensifying regulatory scrutiny of MSO arrangements, while digital health buyers paid significant premiums for platforms demonstrating production-grade AI capabilities and proprietary data assets.
United StatesCorporate/Commercial Law
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

DOJ Continues DEI False Claims Act Enforcement With $25 Million Accenture Settlement

The Department of Justice announced a $25 million settlement with Accenture Federal Services over allegations that the company violated the False Claims Act by falsely certifying compliance with anti-discrimination requirements while allegedly using race or sex in hiring, promotion, and access to professional development programs. This marks the third major DEI-related FCA enforcement action in 2026, following similar settlements with IBM and Deloitte.
United StatesGovernment, Public Sector
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

DOJ's $2 Million Honeywell Settlement Under The Civil Cyber-Fraud Initiative: What Compliance Failures Mean For Defense Contractors

The Department of Justice secured a $2 million settlement with Honeywell Aerospace for allegedly failing to comply with NIST SP 800-171 cybersecurity requirements under a Department of War contract. This case demonstrates how cybersecurity compliance failures can trigger False Claims Act liability even without an actual data breach or cyberattack, and highlights the growing role of whistleblowers in exposing contractors' gaps between contractual obligations and actual security practices.
United StatesGovernment, Public Sector
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

Still Tracking, Still Suing: Website Privacy Litigation After SB 690

California's SB 690 eliminates private lawsuits under CIPA for pen register and trap-and-trace device theories, but website tracking litigation continues under federal wiretapping statutes, ECPA's crime-tort exception, and sector-specific claims. Businesses face ongoing risk from cookies, pixels, and tracking technologies that may unlawfully intercept visitor communications or collect routing data without proper consent.
United StatesPrivacy
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

State Department Pauses Immigrant Visa Appointments Worldwide: What HR Teams Need To Know

The State Department's indefinite pause on immigrant visa appointments has created uncertainty for employers and HR teams managing international talent. While most employment-based green card applications processed within the U.S. remain unaffected, employees awaiting consular processing abroad face significant delays and unanswered questions. Bass, Berry & Sims attorney Nora Katz provides strategic guidance on how HR departments can proactively prepare for this challenging immigration landscape.
United StatesEmployment and HR
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

CAS Board Raises Contract Thresholds To $35 Million And Eliminates CAS 407: What Federal Contractors Need To Know As DoW Demands Cost And Pricing Transparency

The CAS Board has raised contract thresholds to $35 million and eliminated CAS 407, fundamentally changing cost accounting requirements for federal contractors. At the same time, the Department of War is demanding unprecedented cost and pricing transparency through new memoranda requiring actual cost information for negotiations valued at $10 million or more, creating a complex landscape where contractors face fewer formal CAS requirements but heightened scrutiny of their pricing data.
United StatesAccounting and Audit
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

No More SEC Responses To Rule 14a-8 No-Action Requests: What Public Companies Should Know For The Upcoming Proxy Season

The SEC's Division of Corporation Finance has announced it will no longer respond to Rule 14a-8 no-action requests, marking a significant shift in the shareholder proposal process. Companies must still comply with notification requirements under Rule 14a-8(j), but without staff guidance on exclusion decisions, they will need to rely on existing SEC guidance, precedent, and judicial decisions.
United StatesCorporate/Commercial Law
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC