Bass, Berry & Sims attorneys Thad McBride and Faith Dibble authored an article for The National Law Journal analyzing the U.S. Department of Justice’s (DOJ) recent declination involving Bosch and the practical lessons it offers companies navigating export controls compliance and considering voluntary disclosure.
Thad and Faith explain how the Bosch matter illustrates factors DOJ considers when evaluating whether to pursue enforcement action related to export controls violations. They note that the declination thus serves as a useful roadmap for compliance officers and in-house counsel.
Thad and Faith also highlight the increasing importance of maintaining robust export controls compliance programs amid heightened government scrutiny. As enforcement agencies continue to focus on export controls and sanctions-related risks, companies should evaluate whether their compliance frameworks, training programs, and reporting mechanisms are sufficient to detect and address potential violations before they develop into larger enforcement matters.
The full article, “Bosch Declination Gives Export Compliance Officers New Disclosure Playbook,” was published on August 28 in The National Law Journal and is available online.