The note marks the second collective effort by the three agencies to inform the private sector about enforcement trends and provide guidance to the business community on compliance with U.S. sanctions and export laws.

The compliance note describes the voluntary self-disclosure policies of BIS, the Department of Justice’s National Security Division, and OFAC, and highlights recent updates related to these policies. Additionally, the compliance note highlights the Financial Crime Enforcement Network (FinCEN)’s Anti-Money Laundering and Sanctions Whistleblower Program, which incentivises individuals in the United States and abroad to provide information to the government about breaches of U.S. trade and economic sanctions, in addition to breaches of the Bank Secrecy Act.

The note underscores the importance of an effective and robust compliance programme. If a company discovers a potential breach, whether it is an administrative or criminal breach, that company must promptly disclose and remedy the fault. Not only does such reporting make the disclosing company potentially
eligible for significant mitigation, but it also alerts national security agencies to activities that may pose a threat to the national security and foreign policy objectives of the U.S. Government.

“As adversaries leverage increasingly sophisticated efforts to evade international sanctions and export controls, it’s more important than ever to maintain open communication between the public and private sectors,” said outgoing OFAC Director, and incoming FinCEN Director Andrea Gacki. “By taking advantage of our voluntary self-disclosure policy, companies can both help themselves and help us protect our financial
system.”

The full compliance note is here: https://www.bis.doc.gov/index.php/documents/policy-guidance/3302-vsd-tr…