DOJ Adds Incentives for Disclosure in Updated Export Control and Sanctions Enforcement Policy
/In December 2019, the US Department of Justice (DOJ) announced a revised policy regarding voluntary self-disclosure of export control and sanctions violations by business organizations (VSD Policy).
The VSD Policy, issued by DOJ's National Security Division (NSD), sets forth the criteria that DOJ, through NSD’s Counterintelligence and Export Control Section (CES) and in partnership with the US Attorneys' Offices, will now use to determine an appropriate resolution for an organization that makes a voluntary self-disclosure in export controls and/or sanctions matters. Specifically, the VSD Policy encourages business organizations – which now include financial institutions – to self-disclose to NSD "all potentially willful violations of the statutes implementing the US government’s primary export control and sanctions regime."
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