In a recent update to its voluntary disclosure guidance, The US Department of Justice (“DOJ”) highlighted that companies that do voluntarily self-disclose violations may avoid facing a guilty plea or fine.
The guidance notes that the National Security Division (“NSD”) advises that “when a company: (1) voluntarily self-discloses to NSD potentially criminal violations arising out of or relating to the enforcement of export control or sanctions laws; (2) fully cooperates; and (3) timely and app...
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