On 26 July 2023, the Department of Commerce (“DOC”), Department of the Treasury, and Department of Justice (“DOJ”) issued a Tri-Seal Compliance Note1 (“the Note”) summarizing each agency’s approach to the submission of voluntary self-disclosures (“VSDs”) of potential violations of statutes and regulations related to US sanctions, export controls, and other national security laws. The Note also highlights recent updates to these policies that in many cases could have significant implications for...
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