The US Commerce Department’s Bureau of Industry and Security (“BIS”) has announced changes to the voluntary self-disclosure (“VSD”) process and penalty guidelines under the Export Administration Regulations (“EAR”).
The final rule, confirmed in a 16 September 2024 notice, aims to provide BIS with increased flexibility in determining penalties and to simplify the VSD submission process for companies. The tweaks to the earlier interim rule encouraging VSDs seem to show that BIS’s policies announce...
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