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ARTICLE · 23 DECEMBER 2019

New DOJ Sanctions and Export Control Enforcement Policy Incentivizes Self-Disclosure

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On December 13, the U.S. Department of Justice released a revised policy that expands and clarifies certain incentives for voluntary self-disclosure of potential criminal sanctions and export control violations.

United StatesInternational Law
J. Gregory Deis
J. Gregory Deis
Ori Lev
Ori Lev
Margaret-Rose Sales
Margaret-Rose Sales
Mickey Leibner
Mickey Leibner
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On December 13, the U.S. Department of Justice ("DOJ") released a revised policy that expands and clarifies certain incentives for voluntary self-disclosure of potential criminal sanctions and export control violations. The new policy (the "VSD Policy"), which is effective immediately, has important ramifications for companies and their interactions with DOJ regarding potentially willful violations of US sanctions and export control laws. Notably, the DOJ's policy now extends to financial institutions and establishes disclosure benefits in mergers and acquisitions for acquiring companies who discover misconduct through "thorough and timely due diligence." The policy also establishes a presumption of a non-prosecution agreement for companies that meet certain criteria in the absence of aggravating circumstances, as well as substantial mitigation credit where a penalty is warranted.

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