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.