New DOJ Cooperation Guidance on Trade Sanctions and Export Controls

New DOJ Cooperation Guidance on Trade Sanctions and Export Controls

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the new DOJ, National Security Division’s Export Controls and Sanctions Enforcement Policy for Business Organizations. Some of the highlights include: Why is there no declination available? What aggravating factors are different between this policy and the FCPA policy? What is an effective compliance program under this Policy and the OFAC Compliance Framework? Who do you self-disclose to first if you uncover a trade sanctions violation? Is this policy coordinated with other cooperation agreements? What are the lessons learned for a corporate compliance program? What does all this mean for compliance professionals going forward? Resources Matt’s blog post Cooperation for Sanctions Violations in Radical Compliance. Learn more about your ad choices. Visit megaphone.fm/adchoices

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Episoder(434)

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Survey Finds Widespread Retaliation Against Compliance Officers

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1 Jul 26min

Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

Bosch and the Foreign Direct Product Rule: Lessons from the Export Controls and NSD Settlement

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24 Jun 27min

OFAC’s Warning Shot: FTI Consulting Fined for Indirect Dealings with Sanctioned Bank

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3 Jun 23min

An SEC Rollback and a Tribute to Barney Frank

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27 Mai 23min

The DOJ Trainwreck and the Rising Risk Calculus for Compliance and Self-Disclosure

The DOJ Trainwreck and the Rising Risk Calculus for Compliance and Self-Disclosure

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Ohio State and Improper Requests by a President

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Navigating DOJ's Evolving Self-Disclosure Strategies

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29 Apr 23min

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