WorldECR Publishes Fayhee, Grove Article on ‘Tri-Seal’ Compliance Note
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“Need to know basis: understanding recent US compliance guidance,” an article by Akin international trade partners Ryan Fayhee and Tyler Grove has been published by World ECR.
The article looks at the “Tri-Seal” note released by the departments of Justice, Commerce and Treasury to provide companies with guidance on making voluntary self-disclosures (VSDs) of potential sanctions and export controls violations to each agency.
The authors write that this note is the latest action in a series of policy and guidance updates that “have incrementally refined the process and procedures for disclosing potential violations as well as how the agencies will treat those disclosures.”
The article provides a summary of recent guidance and examines considerations for industry, closing with the observation, “Read together, this recent guidance sends a strong signal that the US government is committed to trade enforcement but will provide significant benefits to cooperating companies, such as those submitting VSDs or tips on violations.”
