The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has again sent a clear message that it expects businesses and universities to voluntarily disclose any significant possible violations of the Export Administration Regulations (“EAR”).
On 18 April, the Department of Commerce’s Assistant Secretary for Export Enforcement, Matthew Axelrod issued a memorandum with the subject: “Clarifying Our Policy Regarding Voluntary Self Disclosures and Disclosures Concerning Others”. The mem...
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