U.S. procedures for voluntarily self-disclosing violations of U.S. sanctions and export control laws

Recent updates to certain voluntary self-disclosure policies

Recent updates to certain voluntary self-disclosure policies

The U.S. Department of Justice (DOJ), the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) today issued a compliance note to summarize procedures for voluntarily self-disclosing violations of U.S. sanctions and export control laws to DOJ, BIS, and OFAC.

According to today’s OFAC release, the Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations [PDF 350 KB] (July 26, 2023) explains that self-disclosing potential violations can provide significant mitigation of civil or criminal liability, while also alerting national security agencies to activities that may pose a threat to the national security and foreign policy objectives of the United States.

The compliance note describes voluntary self-disclosure policies that apply to U.S. sanctions, export controls, and other national security laws as well as recent updates that have been made to certain of those policies.
 

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
Principal
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
E: aahanchian@kpmg.com

Christopher Young
Principal
E: christopheryoung@kpmg.com

Gisele Belotto
Principal
E: gbelotto@kpmg.com

George Zaharatos
Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
Principal
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director

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