Compliance Communications Blog

Revised DOJ Policy for Sanction and Export Violations

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12/31/19: The US Department of Justice has issued revisions to its Voluntary Self-Disclosure Policy for sanctions and export control violations. An advisory by law firm Arnold & Palmer explains the revised policy, providing clarity about what it means to companies weighing the benefits of self-reporting...  

According to the article, the potential benefits for organizations may not extend to individuals. The authors write, “… while the reporting company may be more likely to get off the hook under the new presumption, the policy explicitly aims to increase DOJ's ability to prosecute individuals whose misconduct would be difficult to detect or prove without voluntary corporate disclosure.”...

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Revised DOJ Policy for Sanction and Export Violations

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