On March 30, 2026, the US Department of Justice (“DOJ”) National Security Division (“NSD”) announced updated guidance clarifying how companies should report voluntary self-disclosures (“VSDs”) of potential criminal violations of US national security laws, including export controls and sanctions, under DOJ’s new department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”). The announcement reflects NSD’s transition away from its prior division-specific VSD policy in favor of the department-wide CEP released on March 10, 2026 (covered in…
Join us for a webinar on May 22 where we will examine the U.S. Department of Justice’s final rule on protecting Americans’ sensitive data from foreign adversaries. This groundbreaking regulation, which took effect April 11, 2025, represents a novel approach to U.S. national security concerns related to sensitive data transactions with China, Hong Kong, Macau, Russia and other Countries of Concern and Covered Persons. Drawing from our Primer on the DOJ Final Rule, and Article…
Join Baker McKenzie and the Customs and International Trade Bar Association (CITBA) National Security and Sanctions Committee for a discussion of top enforcement priorities in sanctions and export controls, best practices for the private sector, and considerations for voluntary self-disclosure. The panelists for this discussion include Ian C. Richardson, Chief Counsel for Corporate Enforcement for the National Security Division of DOJ; John Sonderman, Director of the Office of Export Enforcement at BIS; and Dallas Woodrum,…
On March 6, 2024, the US Department of Justice (“DOJ”), Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) jointly issued a compliance note titled “Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with US sanctions and export control laws” (“Tri-Seal Compliance Note”). This note highlights longstanding US sanctions and export controls that apply to non-US companies and individuals as well as the…