Updated VSD Policies: How Could this Affect you?
While the United States Trade Representative is currently inundated with Section 301 exclusion requests, the Department of Justiceās (DOJ) National Security Divisionās (NSD) recent update could be encouraging an influx of voluntary self-disclosures (VSDs) to the U.S. export agencies and the DOJ in the near future.
Department of Justice Issues: Guidance on False Claims Act
On May 6, 2019, the Department of Justice (DOJ) issued guidance explaining how the DOJ awards credit to defendants who cooperate during a False Claims Act investigation. The policy states that the DOJ will consider (1) voluntary disclosure of wrongdoing, (2) cooperation in an ongoing investigation, and (3) taking remedial measures in response to the violation.