On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview
Department of Justice

BIS Considers More Public and Expensive Consequences for Companies Violating the EAR
Matthew Axelrod, the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), told a conference held by the Society for International Affairs on May 16, 2022, that his agency is considering major policy changes to its administrative enforcement authorities. Axelrod said the policy changes, expected to be rolled out in the next few months, are intended to incentivize export compliance by corporations under the Export Administration Regulations (“EAR”).
Update: The Department of Justice Withdraws Statement of Interest from Mattresses Case at ITC
Update: On April 30, 2020, the Department of Justice (DOJ) withdrew its “statement of interest” in the ongoing antidumping and countervailing duty investigations on mattresses from various countries. In their filing, the DOJ stated that it, “hereby withdraws that Statement of Interest as not yet ripe.” Currently the U.S. International Trade Commission (“ITC”) is still…
DOJ Takes Unusual Step to Submit Comments in Antidumping and Countervailing Duty Investigation on Mattresses from Vietnam, Thailand, Turkey, Serbia, Malaysia, Indonesia, and Cambodia, and China
The Department of Justice (“DOJ”) filed comments in the U.S. International Trade Commission’s (“ITC”) investigation on whether imports of mattresses from multiple countries are causing injury to the domestic mattress industry. The petition was filed on March 31, 2020, and the Commerce Department initiated the investigations on April 22, 2020. In an unusual step, the…
Did You Just Eat a Problem?
The Foreign Corrupt Practices Act (“FCPA”) became law in 1977, but not until the last decade have the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) aggressively enforced its provisions.