Axelrod Clarifies Self Disclosure Policy

Disclosing results in reduced penalties; not disclosing risks increased penalties. 

Posted 4/19/23

Assistant Secretary of Commerce for Export Enforcement Matt Axelrod issued an update to prior guidance on voluntary self-disclosure of possible violations of Export Administration Regulations (EAR) and disclosures about possible EAR violations by others.   

The most significant change is that while self-disclosure continues to be considered a mitigating factor, the policy now clarifies that deliberate non-disclosure of significant violations will be considered an aggravating factor, increasing potential penalties.

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