The U.S. Justice Department’s National Security Division earlier this month issued guidance for businesses regarding voluntary self-disclosures, cooperation, and remediation in export controls and sanction investigations.
The Justice Department guidance [PDF 92 KB] sets forth the policy of the National Security Division (NSD) to encourage businesses to voluntarily self-disclose criminal violations of the U.S. government’s primary export control and sanction regimes. The NSD guidance applies only to export control and sanctions violations, and is intended to provide greater transparency about what is required from companies seeking credit for voluntarily self-disclosing potential criminal conduct, fully cooperating with an investigation, and remediating. The guidance:
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