Voluntary Self Disclosure 

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Both the Department’s of State (DDTC) and Commerce (BIS) encourage the submission of Voluntary Disclosures (also referred to as Voluntary Self Disclosures) by companies who believe they may have violated the applicable export control regulation. Even the best compliance systems encounter problems. Rather than hiding your mistakes, the U.S. Government encourages companies to submit a voluntary self disclosure. This can be an important step to clear-up past issues and get your organization on the right track towards improved trade compliance.

Voluntary Disclosures can:
  • Serve as a mitigating factor to reduce potential fines and penalties

  • Show the government that your organization is serious about improving

  •  Put your company on a solid foundation of compliance going forward


The U.S. Government carefully reviews Voluntary Disclosures received from companies to determine if violations of the regulations have occurred and to determine the appropriate corrective action. Most Voluntary Disclosures are resolved by means other than the issuance of an administrative penalty. However, in instances in which the U.S. Government determines that the issuance of an administrative penalty is appropriate for the resolution of a violation, the regulators afford the submission of a Voluntary Disclosure "great weight" in assessing and mitigating the penalty, and in most cases the fines and other administrative penalties may be significantly reduced.


Given the scope of today’s global business and the complexity of the ITAR and the EAR, every exporter will potentially have violations. But it is worth noting that voluntary disclosures with State or Commerce generally do not result in fines, penalties or Consent Agreements. In most cases, transparency and thoroughness of voluntary disclosures, combined with a well designed, and functioning compliance program, are a company’s best defense in avoiding costly administrative proceedings and settlements.


How we can help:
  •           Create a Voluntary Self Disclosure on behalf of the company and submit to the relevant government agency.

  • ·         Conduct a thorough examination to identify all of your problems

  • ·         Identify mitigating factors to help reduce penalties

  • ·         Work with you to develop and implement corrective actions

  •     Acting as a liaison with government officials to resolve and close-out your case