Regulation

BIS: further enhancements to VSD policy for minor/technical dual-use violations

Issue 40
February 2024

Author
Alex LamyAlexandra KumarPaul Amberg
+ About author

Alex Lamy (Partner, Washington, DC) is a member of the international trade practice at Baker McKenzie. www.bakermckenzie.com

Alexandra Kumar (Associate, Washington, DC) is a member of the international trade practice at Baker McKenzie. www.bakermckenzie.com

Paul Amberg (Partner, Madrid) is a member of the international trade practice at Baker McKenzie. www.bakermckenzie.com

On 16 January 2024, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) announced1 further enhancements to its voluntary self-disclosure (“VSD”) policy under the Export Administration Regulations (15 C.F.R Parts 730–774, the “EAR”). These enhancements build upon previous VSD developments announced on 30 June 30 2022 and 18 April 2023, in order to increase the efficiency and effectiveness of the VSD process.
Assistant Secretary for Export Enforcement, Matthew S. Axe...

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