DOJ Issues Updated Export Control and Sanctions Enforcement Policy for Business Organizations: DOJ Policy Includes Concrete Benefits for Voluntary Self-Disclosure but Requires that Disclosure Be Made Directly to DOJ

Sullivan & Cromwell LLP - December 19, 2019
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On December 13, 2019, DOJ announced a new policy that encourages companies to voluntarily self-disclose possible sanctions or export control violations.  The policy now applies to financial institutions.  When certain aggravating factors are not present, the policy creates a presumption that violations will be resolved by a non-prosecution agreement without a fine when a company discloses, cooperates, and remediates in compliance with the policy’s terms, but only if the disclosure is directly to DOJ.