Voluntary Self-Disclosure: Is The Value Self-Evident?

Takeaways

• The DOJ, BIS and OFAC released a joint compliance note highlighting the benefits of voluntary self-disclosure for potential violations of U.S. sanctions, export controls and national security laws.
• The joint compliance note highlights the continued enforcement focus on sanctions, export controls and national securities laws, the commitment to coordination between agencies and the importance of robust compliance programs adequate to address the risks that a company faces.
• BIS and OFAC voluntary disclosure procedures are well-established and frequently used to manage risk. The DOJ has had less success in encouraging voluntary disclosures, but is hoping for increased disclosures in light of policy updates and major investments in criminal enforcement of sanctions and trade controls.