DOJ Export Controls and Economic Sanctions Enforcement Guidance Likely to Impact Government Contractors, Parallels FCPA Pilot Program

Members of the Steptoe International Regulation and Compliance team, Tom Best, Jack Hayes, Andy Irwin, Ed Krauland, and Lucinda Low co-authored “DOJ Export Controls and Economic Sanctions Enforcement Guidance Likely to Impact Government Contractors, Parallels FCPA Pilot Program” for Thomson Reuters Briefing Papers (No. 16-12).  The paper discusses a memorandum by the US Department of Justice’s National Security Division, which sets out the policy framework for negotiated resolutions of export control and economic sanctions investigations with potential criminal liability.