Part III: Voluntary Disclosures: The Messy Issues with “Coming Clean”

Government enforcement agencies tout the benefits of voluntary self-disclosures of export violations by a company:  greatly reduced penalties and public exposure.  But voluntary disclosure comes with significant costs and considerations for businesses, which mean that the programs are not for every violator.  Do you know when your company should “come clean” and when you should stay silent?

In this third and final chapter of ECTI’s special three-part webinar series on preparing for, and handling, export enforcement actions, we will address the ins and outs of voluntary disclosure programs for export violations.  We will discuss the costs, benefits, and considerations that should go into your company’s decision-making process when it comes to voluntary disclosure.  We will describe the factors that once led a senior official in the U.S. Department of Justice to comment, “If you can … investigate, remediate, properly document [the violation], I think you can responsibly deal with it and not tell us about it.”

Specifically, this webinar will:

• Describe the benefits of voluntary self-disclosure of export violations under the various enforcement régimes (BIS, DDTC, OFAC, and CBP/Census);
• Discuss the considerations that should go into your company’s decision whether to disclose or not disclose its violations, including the cost to your company and the enforcement ripple effects that could result from a disclosure;
• Present the procedures that your company should use for the voluntary disclosure process to ensure maximum benefits with minimum costs;
• List the “dos” and “don’ts” of voluntary disclosure to ensure that your company’s well-intentioned actions do not result in unforeseen problems; and
• Describe those unique situations when you effectively must voluntarily disclose your export violations.

As with the other webinars in this series, Part I: Planning for Government Export Enforcement Measures & Part II: Responding to Government Export Investigations and Subpoenas, this installment will be especially valuable for companies that:

• Operate in heavily regulated and sensitive industries such as defense, energy, and cutting-edge technology;

• Manufacture, sell, or distribute merchandise that is subject to licensing or special scrutiny from BIS, DDTC, or other government agencies;
   
• Have a product presence (or are expanding their footprint) in emerging markets such as Latin America, the Middle East, and Southeast Asia, and in those counties known for transshipment issues or doing business with embargo and sanction countries;

• Are third-party logistics providers, freight forwarders, and shipping agents which could find themselves under investigation for violations committed by their clients; and

• Have executives and export personnel who would (finally) like to get a good night’s sleep.

This webinar will provide PowerPoint slides and include live video and commentary from Stephen Wagner, who specializes in international trade law and government regulatory and enforcement matters. Webinar participants are invited to submit questions during the webinar; the final 30 minutes of the webinar will be allotted to answering attendees' questions.

Register Now **Contact us for special payment arrangements. 

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**Each registrant will receive a copy of the presentation, certificate of completion and access to the webinar recording.

Did you miss Part I and Part II of this amazing webinar series on export enforcement matters?  It’s not too late!

In case you missed it, Part I of the series, Planning for Government Export Enforcement Measures is available from ECTI.  This valuable webinar describes how your company can be proactive and put the policies, procedures, and resources in place to effectively handle any government enforcement matter.  We discuss the rights and obligations of the company in various enforcement scenarios and the benefits that can be gained from preparing an enforcement response plan today.

Also available from ECTI is Part II of the webinar series, Responding to Government Export Investigations and Subpoenas. This session focuses on that critical first moment when your company first learns of a government investigation, first receives a subpoena for export documents, or first has enforcement agents arrive (unannounced) in your lobby.  We will give you the critical information and tools your company needs to gain control of an enforcement action in order to mitigate possible sanctions and improve your overall export compliance posture.