On October 2, the Department of Justice’s (DOJ) National Security Division (DOJ NSD) issued a memorandum announcing the policy framework for negotiated resolutions with companies involved in economic sanctions and export control investigations with a criminal dimension. The policy statement titled “Guidance Regarding Voluntary Self-Disclosures, Cooperation, and Remediation in Export Control and Sanctions Investigations Involving Business Organizations” (the Guidance), is intended to create incentives for companies investigating potential economic sanctions and export controls concerns to voluntarily disclose them to DOJ NSD. The new policy indicates that in cases where companies meet cooperation, remediation, and compliance standards, DOJ NSD will provide significantly more favorable resolution terms than would otherwise have been available. For more information, please see our advisory.
