On July 26, 2023, the U.S. Department of Justice’s (DOJ) National Security Division, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Tri-Seal Compliance Note regarding the self-disclosure of potential violations of U.S. sanctions and export controls, as explained by the detailed post on JD Supra.
The Compliance note aims to provide a clear framework for corporations involved in potential violations of U.S. sanctions and export controls. It pertains to the voluntary self-disclosure (VSD) policies, which act as a guideline for corporations in their proactive efforts toward legal compliance.
Following details of the voluntary self-disclosure policies are crucial:
- The policy provides a clear guideline for corporations who want to disclose potential violations. This could make the process smoother and faster.
- The policy provides clarity on what constitutes a voluntary disclosure. It also clarifies the benefits and consequences of making such a disclosure.
- The policy looks to incentivize good corporate governance by encouraging corporations to disclose potential violations.
- The policy provides clarity on how potential violations would be handled by the respective financial authorities.
This Tri-Seal Compliance note is a promising step towards creating an environment where corporations are encouraged to take responsibilities for their actions. The hope is that the effect of this Note on voluntary self-disclosure will foster a climate of transparency and legal compliance among corporations, thus ultimately bolstering the strength of the U.S. economy.