THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

March 2012

Considerations in how to approach voluntary disclosures of export violations

Voluntary disclosures of export violations to the various government agencies may make good business sense but their repercussions are not always what one might expect. Jason Waite and Diego Marquez..

The voluntary disclosure of an export violation can be an effective tool for companies and individuals looking to mitigate the potential consequences for violations of U.S. export control laws. Given the heightened focus on enforcement in recent years and the increased civil and criminal penalties for export violations, the stakes in approaching voluntary self-disclosures have grown. The preparation and submission of a voluntary disclosure requires exporters to consider many factors, and it is critical that exporters or otherwise concerned parties fully understand such factors before deciding to move ahead with a disclosure and in designing the best possible approach to...

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