Self-Disclosing Criminal Export Violations: The New Guidance
Law360, New York (October 26, 2016, 2:26 PM EDT) -- John P. Barker
Emma Dinan The U.S. Department of Justice's National Security Division recently issued guidance on how the DOJ's approach to cooperation from business organizations will apply in the national security context. The guidance reiterates the DOJ's commitment to pursue willful violations of export control and sanctions laws by corporate entities and their employees, and clarifies that the directives to hold corporate entities criminally liable and to prosecute culpable employees individually in criminal cases will apply with equal force in cases involving threats to national security. What is new in this guidance is the listing of "aggravating circumstances" involving...
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