- US Departments of Treasury, Commerce, and Justice have released a Tri-Seal Compliance Note on voluntary self-disclosure (VSD) of potential violations of US sanctions, export controls, and other national security laws.
- The VSD Note summarises the respective agency VSD policies that apply to these laws and recent updates made to certain policies.
- The VSD Note does not announce changes to these VSD policies and treats each VSD regime separately.
- The Note emphasises that companies should promptly disclose and remediate to earn the benefits of the VSD policies.
- The BIS’s VSD policies for potential violations of US export controls laws have recently been updated with a dual-track system.
- The OFAC’s VSD policies for potential violations of US sanctions laws have not been recently updated and continue to incentivise the submission of VSDs.
- The DOJ NSD’s VSD policies for potential criminal violations of US export controls and sanctions laws have recently been updated as part of the DOJ’s efforts this year to implement consistent VSD policies across the DOJ.
Source Baker & McKenzie
