Clifford Chance

Clarifications and Incentives: Commerce Issues Clarification Memorandum on Voluntary Self-Disclosures and Disclosures Concerning Others

April 24, 2023

On April 18, 2023, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Commerce Department's Bureau of Industry and Security ("BIS"), issued a Memorandum "Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others" ("VSD Memorandum").

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