U.S. Department of Commerce’s BIS Enhances Its Enforcement Discretion: Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps, and Amends Penalty Guidelines

In this article, published in The Global Trade Law Journal, Thompson Hine’s Francesca M.S. Guerrero, Samir D. Varma, Aaron C. Mandelbaum, and Scott E. Diamond discuss the fi­nal rule published recently by the Department of Commerce’s Bureau of Industry and Security revising voluntary self-disclosure provisions and penalty guidelines of the Export Administration Regulations.

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