Regulatory: New DOJ Guidance on Voluntary Self-Disclosures and OFAC’s Framework for Compliance

September 15, 2020 4:45pm

Jay Bratt
Chief at Counterintelligence and Export Control Section
US Department of Justice (USA)

Michael Zolandz
Dentons (USA)

  • Factors to consider when deciding whether to disclose and to whom
  • Key considerations under suspected breaches and multiple parties
  • Understanding the role of other parties, their regulatory requirements and risk appetite
  • Mapping out the timing of submission to fully understand the scope of the problem
  • Identifying OFAC mitigating and aggravating factors
  • Understanding the base penalty matrix under the multi-jurisdictional regulatory regimes