Overview
Global Investigations Review (GIR) cited Wendy Wysong in an article titled "Success of Sanctions Self-Reporting Policy Could Hinge on Banks." The article, published December 17, discusses the Department of Justice's (DOJ) fresh push to encourage banks to self-report on sanctions and export control violations. The DOJ said it will not grant a company credit for self-disclosing if it reports the same issue to another agency first. However, lawyers say that early in an investigation a potential issue may only look like a regulatory concern but could later develop into a criminal matter.
Wysong tells GIR that the policy contains several other points that require fleshing out, including if a company can reduce its potential penalty without self-reporting and if the department will publish any non-prosecution agreements it agrees with companies.
The full article can be read at GIR (subscription required).
