Presented by Jon Yormick
Export control reform means that more companies, commodities, software, and technologies fall under the jurisdiction of the Bureau of Industry & Security (BIS) and the investigative authority of its Office of Export Enforcement Special Agents. Is an outreach visit a friendly “get to know your company” visit or something more? Voluntary disclosures of export violations may involve multiple federal agencies, each with different requirements and a proposed rule would align BIS penalty assessment with the Office of Foreign Assets Control’s (OFAC) penalty matrix.
Jon Yormick, Special Counsel – Customs & International Trade, Phillips Lytle LLP, will discuss how to treat outreach visits, considerations for voluntary disclosures, responding to Office of Export Enforcement investigations, proposed charges, and negotiating administrative penalty settlements.