By Maya Lester QC & Michael O’Kane

New US DOJ policy to encourage disclosure of export control & sanctions violations

The US Department of Justice has issued a revised policy for business organisations to encourage voluntary self-disclosure of all potential export control and sanctions violations: the “VSD Policy”. It became effective on 13 December 2019. Press release here, and further information here. The key changes are: Where companies are cooperative, and disclosure is voluntary, timely, and remediate, there will be …

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About Michael O'Kane

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Michael is Senior Partner at Peters & Peters LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters & Peters LLP...

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