You’d rather it went away… but it just won’t. The message from the DOJ and other regulators is clear: Disclosing a sanctions or export control violation more than makes sense. BIS has said that its Office of Export Enforcement will consider the deliberate non-disclosure of a significant possible export control violation to be an aggravating factor that may trigger “sharply increased” penalties.
In this session, Don Pearce, retired BIS Special Agent and founder of specialist trade consultancy Sentinel LLC, will share his insights on the best way forward when evidence of an export control/sanctions violation comes to light. It’s a time for clear thinking and good practice, all clearly recorded for later reference.
Understanding and implementing a good course of action will be key. For, as Don says, “The decisions made at the point of discovery can mean the difference between a hefty fine and a sternly worded warning letter.”
