Partner Giovanna Cinelli was featured in a Law360 article reviewing major international trade developments in 2023. Giovanna discussed the US Department of the Treasury, US Department of Commerce (DOC), and US Department of Justice’s moves to encourage companies to voluntarily disclose potential violations in return for a reduced punishment. She delves into how their efforts align with the DOC’s Bureau of Industry and Security’s practice of not allowing, in many cases, settlement unless a violator admits fault.
"These factors together have changed the risk calculation for conducting internal export investigations and for managing the decisions related to disclosures," said Giovanna. "This approach increases the costs related to export compliance and counsels for a broader deeper bench of resources who can build and manage effective compliance processes and meet the government's focus on programs that 'identify, prevent and mitigate' export control violations.”