Good Practice

VSD: The first 48 hours – The actions you should take upon discovery of a potential EAR violation

Issue 14.
June 2021

Author
Donald Pearce
+ About author

Donald Pearce, a retired Special Agent from the US Commerce Department’s Bureau of Industry and Security, is the founder of Sentinel LLC, a consultancy focused on the intersection of international trade, technology, geopolitics, and security, and is also a Senior Advisor in the Global Risk, Monitorship, and Investigations Practice at trade advisory firm, Torres Trade Advisory. don@torrestradeadvisory.com

It is often said that it is not if a compliance officer will discover a potential violation of the regulations, but when (and how often). Companies with stellar reputations and a top-down commitment to compliance can still make mistakes, and perhaps the most crucial role of the compliance officer is to catch them early and often. The decisions made at the point of discovery can mean the difference between a hefty fine and a sternly worded warning letter. So what should you do when you discover ...

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