Handling Violations & Voluntary Disclosures

Companies that handle export controlled technology, software, or commodities are bound to run afoul of the export control regulations at some point – the question is, what do you do next?  Our international trade attorneys, including Clif Burns, a seasoned export control practitioner, and Chandler Leonard, a former Compliance official with DDTC and OFAC, will explore how and why companies make the decision to disclose potential violations of U.S. export controls to the government, and will detail best practices for initiating internal reviews and making disclosures.  We will also explain the different disclosure and enforcement regimes at the Departments of State, Commerce, Treasury, and Justice, and will distinguish between civil and criminal disclosures for each.