DOJ, Commerce, and Treasury Issue Advisory on Voluntary Self-Disclosure Policies for Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s National Security Division, the U.S. Department of Commerce’s Bureau of Industry and Security, and the U.S. Department of the Treasury’s Office of Foreign Assets Control jointly issued a compliance note summarizing voluntary self-disclosure policies applicable to U.S. sanctions, export controls, and other national security laws.

The note underscores the U.S. government’s focus on investigating and prosecuting violations of sanctions and export controls laws. While based largely on existing guidance and authorities, the note highlights the role of private-industry “gatekeepers” in sanctions and export control compliance, and U.S. authorities’ increasing emphasis on disclosures in conjunction with potential enforcement.

Please click here to read the full alert memorandum.