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Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations

Date issued: Jul. 26 2023

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[Date: July 26, 2023]

Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note:

Voluntary Self-Disclosure of Potential Violations

OVERVIEW

U.S. businesses are at the vanguard of technological advancements: inventing new materials, making scientific breakthroughs, and otherwise advancing U.S. technological and financial leadership.1 As key participants in international trade and finance, businesses also play a critical role in identifying threats from malicious actors and helping to protect our national security by complying with U.S. sanctions, export controls, and other national security laws. It is critical that businesses work together with the U.S. Government to prevent sensitive U.S. technologies and goods from being used by our adversaries and to prevent abuse of the U.S. financial system by sanctioned individuals, entities, and jurisdictions.

Compliance with sanctions, export controls, and other national security laws is paramount. If a company discovers a...

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TURBOFAC Commentary (498 words)

Notes:

1) Apart from the show of cross-agency cooperation in issuing the joint release, this Compliance Note does not appear to break new ground as it relates to the sanctions related VSD policies of OFAC and the DOJ's National Security Division. See the DOJ policy recapped here at NSD Enforcement Policy for Business Organizations (Mar. 2023 - Second Reissuance), and see OFAC's VSD policies at section I(I) of Appendix A to Part 501, the relevant text of which is reproduced below:

"I. Voluntary self-disclosure means self-initiated notification to OFAC of an apparent violation by a Subject Person that has committed, or otherwise participated in, an apparent violation of a statute, Executive order, or regulation administered or enforced by OFAC, prior to or at the same time that OFAC, or any other federal, state, or local...