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Voluntary Disclosures of Export Violations

The recent settlement agreement entered in the EP MedSystems matter (described below) does little to refute the common wisdom that the Department of Commerce's Bureau of Industry and Security ('BIS') treats voluntary disclosures of export violations more harshly than other agencies that regulate exports from the United States. It also illustrates a potential, but avoidable, peril in the two-step voluntary disclosure process urged by BIS and other federal agencies. Finally, it serves as yet another example of the regulatory minefield that U.S. export laws present for U.S. companies with foreign subsidiaries.

21 minute read January 31, 2007 at 09:35 AM
By
Robert Clifton Burns
Voluntary Disclosures of Export Violations

The recent settlement agreement entered in the EP MedSystems matter (described below) does little to refute the common wisdom that the Department of Commerce's Bureau of Industry and Security ('BIS') treats voluntary disclosures of export violations more harshly than other agencies that regulate exports from the United States.

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