Careers

Diversity, Equity & Inclusion

Experience

Innovation

Interactive Maps

Locations

About

Pages

Meet our team of innovators
Ask us how we do it

Professionals

Insights

Services

Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

Home | Thompson Hine LLP

Atlanta

Chicago

Cincinnati

Cleveland

Columbus

Dayton

Los Angeles

Minneapolis

New York

Silicon Valley

Washington, D.C.

On December 13, 2019, the U.S. Department of Justice (DOJ) released a <a href="https://www.justice.gov/nsd/ces_vsd_policy_2019/download" target="_blank" rel="noopener">revised policy</a> for companies regarding voluntary self-disclosures of export control and sanctions violations. The revised policy was effective on the date of its release and will be formally incorporated into the <a href="https://www.justice.gov/jm/justice-manual" target="_blank" rel="noopener">Justice Manual</a>. In releasing the revised Voluntary Self-Disclosure Policy (VSD Policy), Assistant Attorney General for National Security John C. Demers stated, &ldquo;Protecting our nation&rsquo;s sensitive technologies and preventing transactions with sanctioned entities are DOJ priorities, but we cannot succeed alone ... We need the private sector to come forward and work with DOJ. The revised VSD Policy should reassure companies that, when they do report violations directly to DOJ, the benefits of their cooperation will be concrete and significant.&rdquo;
Key Notes:
<ul>
<li>The revised Voluntary Self-Disclosure Policy builds on the guidance DOJ&rsquo;s National Security Division (NSD) issued in October 2016.</li>
<li>This revised policy signals DOJ&rsquo;s continued emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of a non-prosecution agreement and significant reductions in penalties.</li>
<li>The policy was effective on December 13, 2019, and applies only to export control and sanctions matters brought by the NSD&rsquo;s Counterintelligence and Export Control Section.</li>
</ul>
Continue reading this client bulletin in <a href="https://www.thompsonhine.com/publications/doj-revises-export-control-and-sanctions-enforcement-policy-for-business-organizations" target="_blank" rel="noopener">HTML</a> or <a href="https://www.thompsonhine.com/uploads/1345/doc/International_Trade_Update_-_DOJ_Revises_Export_Control_and_Sanctions_Enforcement_Policy_for_Business_Organizations.pdf" target="_blank" rel="noopener">PDF</a> format.

core/freeform

SmarTrade

Department of Justice Revises Export Control and Sanctions Enforcement Policy for Business Organizations