Good Practice

Conquering fears of US export control voluntary disclosures

STEPTOE: OUTSIDE COUNSEL

Mistakes are not uncommon given the complexity of export controls compliance under the US Export Administration Regulations (“EAR”) and the US International Traffic in Arms Regulations (“ITAR”). Even with the best intentions, training, and automated systems, compliance professionals periodic­ally receive “red alerts” of potential violations.

How should you approach a potential voluntary disclosure when you uncover an EAR- or ITAR-related error?

Don’t panic. Man...

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Jonny Test