DOJ Issues Updated Export Control And Sanctions Enforcement Policy For Business Organizations

On December 13, 2019, the U.S. Department of Justice (DOJ) announced the release of a revised policy for business organizations regarding voluntary disclosures of export control and sanctions violations (VSD Policy) where there are potentially “willful” violations. The updated policy is intended to incentivize businesses to voluntarily self-disclose any such potentially willful violations and to cooperate fully with the government. The revised policy also reflects a recent push from government organizations to foster a greater public-private partnership to promote national security.

The policy states that “business organizations and their employees are at the forefront of the effort to combat export control and sanctions violations. As the gatekeepers of our export-controlled technologies, business organizations play a vital role in protecting our national security.” The policy’s stated goals are to deter and prevent export control and sanctions violations, encourage