Global Trade & Foreign Policy Insights

On February 28, President Biden issued a major new executive order. The E.O. directs the Attorney General to issue regulations within 180 days that prohibit or restrict U.S. persons from engaging in transactions with “countries of concern” involving the transfer of Americans’ bulk sensitive data or U.S. government-related data. 

On December 13, 2019, the U.S. Department of Justice (DOJ) announced the release of a revised policy for business organizations regarding voluntary disclosures of export control and sanctions violations (VSD Policy) where there are potentially “willful” violations. The updated policy is intended to incentivize businesses to voluntarily self-disclose any such potentially willful violations and to cooperate fully with the government. The revised policy also reflects a recent push from government organizations to foster a greater public-private partnership to promote national security.