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voluntary self disclosure
NSD “go to” agency for voluntary self-disclosure; regime confusion?

NSD “go to” agency for voluntary self-disclosure; regime confusion?

Come to us first. That was the message from the National Security Division, which said last week that companies should voluntarily self-disclose violations of national security laws directly to them first. From telecom and sanctions violations to export controls and CFIUS, the NSD will be the “VSD” entry point.

For second time, DOJ declines to prosecute due to self-disclosure

For second time, DOJ declines to prosecute due to self-disclosure

Last week, the National Security Division of the Department of Justice announced it would decline prosecution of a company whose employee violated export control rules. The reason: The company’s voluntary self-disclosure and “exceptional and proactive cooperation.” Details, lessons inside.