NSD Enforcement Policy for Business Organizations (Mar. 2023 - Second Reissuance)

Date issued: Mar. 01 2023

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TURBOFAC Commentary (241 words)

Notes:

1) Consolidated Comment on Guidance Regarding Voluntary Self-Disclosures, Cooperation, and Remediation in Export Control and Sanctions Investigations Involving Business Organizations (Oct. 2016), Department of Justice Export Control and Sanctions Enforcement Policy for Business Organizations (Dec. 2019 - First Reissuance) and NSD Enforcement Policy for Business Organizations (Mar. 2023 - First Reissuance).

On October 2, 2016, the DOJ issued its first formal guidance document setting out its policy concerning voluntary disclosures for sanctions violations. The 2016 document was superseded by the 2019 document and later the 2023 document, but the 2016 and 2019 documents remain on the DOJ website (as of 3-2023). Note that the DOJ removed the “examples” in the 2016 document when it issued the 2019 document, suggesting that one or more of them may no longer reflect DOJ...