On 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanctions Enforcement Policy for Business Organizations (the Enforcement Policy).
The Enforcement Policy sets forth the criteria to be used by DOJ – through NSD's Counterintelligence and Export Control Section (CES), in partnership with U.S. Attorney's Offices nationwide – to determine "an appropriate resolution" for an organization that makes a voluntary self-disclosure (VSD), directly to NSD, for "potentially willful violations" of United States export control and sanctions law. The Enforcement Policy reflects a clear effort by NSD to increase its cooperation with the private sector by providing more clearly defined benefits for companies that make voluntary self-disclosures and by more closely aligning the NSD guidance with recent guidance issued throughout DOJ.
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