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