On September 12, 2024, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule to amend the Export Administration Regulations (EAR) revising provisions related to the voluntary self-disclosure (VSD) process for persons who believe that they may have violated the EAR, or any order, license or authorization issued thereunder. The
Voluntary Self-Disclosure
BIS Announces Further Updates to OEE’s Voluntary Self-Disclosure Process for Minor Violations
By Jeffrey L. Snyder, Jackie Schaeffer & Dilan Wickrema on
On January 16, 2024, Bureau of Industry and Security (BIS) Assistant Secretary for Export Enforcement Matthew Axelrod announced further updates to the EAR voluntary self-disclosure (VSD) process, all designed to incentivize the prioritization of export control compliance resources of the U.S. Government, industry, and academia.
The Office of Export Enforcement (OEE) released a Memorandum to…
DOJ, OFAC, and BIS Issue “Tri-Seal Compliance Note” Focusing on Voluntary Self-Disclosures
What You Need to Know
New U.S. Department of Commerce Policy Further Incentivizes Disclosures of U.S. Export Control Violations
On April 18, 2023, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) released a memorandum entitled, “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (the “April Memo”). The April Memo highlights additional penalties and incentives to encourage exporters – and whistleblowers – to disclose potential violations of the…