Good Practice

Voluntary disclosures: Submission is not the end

Issue 12
April 2021

Author
Elizabeth ShinglerSteven BrothertonLouis Conde
+ About author

Elizabeth Shingler (Richmond) is a Senior Manager in the Global Export Controls and Sanctions practice of KPMG LLP. eshingler@kpmg.com

Steven Brotherton (San Francisco) is a Principal in the Global Export Controls & Sanctions practice of KPMG LLP and leader of the service line. sbrotherton@kpmg.com

Louis Conde is an Associate at KPMG’s Trade & Customs Practice.

KPMG: SMART PRACTICE
When it comes to export violations, voluntary self-disclosures are used to report potential violations to a government agency and can be an effective tool in mitigating consequences for violating export controls or sanctions laws. From low-level violations to large-scale ones, voluntary self-disclosures enable companies to report compliance violations while potentially limiting penalties. However, submitting the disclosure is only the first step towards improved compliance. ...

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