Regulation

DOJ’s National Security Division breathes life into updated voluntary disclosure policy with first declination

Issue 44.
June 2024

Author
Linklaters
+ About author

Adam Lurie (New York/Washington, DC) is a Partner at Linklaters, where he heads the US litigation practice. Ashley Latham is a Senior Associate in the firm’s New York office. Michael Lamson is Counsel and Simon Song is an Associate in the firm’s Hong Kong office. www.linklaters.com

On 22 May 2024, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”) announced1 its very first declination to prosecute2 under NSD’s Enforcement Policy for Business Organizations (the “NSD Enforcement Policy”).3 The case involved MilliporeSigma, a subsidiary of multinational science and technology company Merck KGaA, and a MilliporeSigma salesperson, for allegedly conspiring with others to divert products to China using falsified export documents.
DOJ’s declination underscor...

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