Overview
On July 28, 2023, Global Investigations Review quoted economic sanctions and CFIUS partner Brian Fleming in an article titled, "Latest DOJ, Treasury, Commerce guidance implies more than it updates." The article discusses the recent Compliance Note on voluntary self-disclosures issued by the US Department of Commerce, Treasury, and Department of Justice, which is a joint effort by the agencies to have companies help the US achieve its foreign policy objectives and maintain national security.
"It's difficult to decide whether to report to the DOJ, particularly soon after you've discovered wrongdoing," Brian says of the increased guidance. On the other hand, he notes, "the agencies are increasing the negative consequences for not self-reporting misconduct."
Read the full article at Global Investigations Review.
