Overview
Partner Meredith Rathbone was quoted in an article published by Foreign Investment Watch, titled “BIS updates VSD process, penalties; names first-ever enforcement chief." The article discusses the appointment of the Bureau of Industry and Security's (BIS) first ever Chief of Corporate Enforcement, along with the finalized penalty guidelines and process for handling VSD's (Voluntary Self-Disclosures).
Regarding the penalty guidelines around VSDs, Meredith said "the increased penalty caps and generally more aggressive feel of communications coming out of BIS's enforcement branch will give some companies pause about disclosing," and that legal and compliance teams will have to make some "hard decisions."
Read the article at Foreign Investment Watch. (subscription required)
