In the ever-evolving and complex world of economic sanctions, voluntary self-disclosure is frequently the best long-term strategy for any company that discovers a violation of a sanctions regime. The more difficult task is to assess the costs and benefits of self-disclosure in cases where the conduct falls into a gray area. We explain the complex relationship between voluntary self-disclosure and the Office of Foreign Assets Control’s enforcement response in a chapter recently published in the International Comparative Legal Guide.
Read the chapter here.