Disclosure Strategy After BIS Export Control Policy Update

By Eric Sandberg-Zakian, Blake Hulnick and Lisa Ann Johnson (July 15, 2022, 2:53 PM EDT) — On June 30, Assistant Secretary of Commerce for Export Enforcement Matthew Axelrod issued a memorandum announcing a revised approach to administrative enforcement by the U.S. Department of Commerce Bureau of Industry and Security.[1]

The revised approach, which BIS had foreshadowed by announcing a series of policy reviews over the last several months, could complicate the calculus companies have long employed in deciding whether to disclose past export violations to BIS voluntarily.

Citing, among other factors, an increasing threat from nation states including China, Russia, Iran and North Korea, Axelrod announced four significant enforcement policy changes that should resolve some administrative violations…

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