DOJ, OFAC, and BIS Issue “Tri-Seal Compliance Note” Focusing on Voluntary Self-Disclosures By Caroline Brown, Jana del-Cerro, Carlton Greene, Jason Prince, Laura Schwartz, Anand Sithian, David H. Favre & Richard Stella on August 2, 2023 Posted in Bureau of Industry and Security (BIS), Department of Justice, Office of Foreign Assets Control (OFAC), Voluntary Self-Disclosure What You Need to Know Key takeaway #2 Failure to initiate an internal investigation promptly after discovering a potential export controls or sanctions …