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On April 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a policy memorandum clarifying the Office of Export Enforcement’s (OEE) policies...
In concert with the Department of Justice’s (DOJ) focus on voluntary self-disclosure of corporate misconduct, as well as DOJ’s commitment to addressing sanctions evasion, export control...
In concert with the Department of Justice’s (DOJ) focus on voluntary self-disclosure of corporate misconduct, as well as DOJ’s commitment to…
On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Office of Export Enforcement (“OEE”) released a set of “policy clarifications” in the...
If it’s significant, and you don’t disclose, you can be disadvantaged by non-disclosure being an “aggravating factor,” even if you take prompt actions to fix the problem you disclose.