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Voluntary Self-Disclosures of Export Violations Under Review

Tuesday, January 28, 2014
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security is soliciting comments through Feb. 27 on the proposed extension of an information collection concerning voluntary self-disclosures of violations of the Export Administration Regulations. BIS states that VSDs strengthen its enforcement efforts by allowing it to conduct investigations of the disclosed incidents faster than would otherwise be the case. BIS evaluates the seriousness of the violation and (1) informs the person making the disclosure that no action is warranted, (2) issues a warning letter, (3) issues a proposed charging letter and attempts to settle the matter, (4) issues a charging letter if settlement is not reached, and/or (5) refers the matter to the Department of Justice for criminal prosecution.

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