In our latest article for The National Law Journal, we examine the U.S. Department of Justice’s recent Bosch declination and what it reveals about DOJ’s approach to export controls enforcement, compliance program effectiveness, and voluntary self-disclosure decisions.
We explain how the Bosch matter provides valuable insight into the factors DOJ considers when determining whether to pursue enforcement action for export controls violations. For compliance officers, in-house counsel, and corporate compliance teams, the declination serves as a practical roadmap for evaluating disclosure obligations, strengthening internal controls, and mitigating enforcement risk.
As government scrutiny of export controls and sanctions compliance continues to increase, companies should take a fresh look at their compliance frameworks, employee training, reporting mechanisms, and investigation procedures to ensure potential issues are identified and addressed early.
Read our full article, “Bosch Declination Gives Export Compliance Officers New Disclosure Playbook,” published in The National Law Journal on August 28.