Own It Exporters

Many of our posts focus on the basics of export compliance. Due diligence is required when filing EEIs, classification of Schedule B and ECCNs, and Country of Origin determination. An Export Compliance Program (ECP) is highly recommended as well as red flag screening, training, and audits. In spite of best efforts, mistakes will be made. In these cases a Voluntary Self-Disclosure is a smart move. Here is some info from the BIS (Bureau of Industry and Security) website:

Parties who believe they may have committed a violation of the EAR are encouraged to submit a Voluntary Self-Disclosure (VSD) to BIS. VSDs are an important indicator of a party’s desire to bring their export activities into compliance, and also may provide important information to BIS helping to identify foreign proliferation networks. Parties submitting VSDs may be eligible for significant reductions in administrative penalties, and those with well-implemented EMCPs may expect further significant reductions of administrative penalties. Procedures for submitting VSDs may be found in Section 764.5 of the EAR. The procedures detailed in Section 764.5 do not apply to VSDs involving violations of the antiboycott provisions of the EAR. Procedures for submitting VSDs for boycott violations are found in Section 764.8 of the EAR.

Contact mitch@ for assistance in submitting VSDs.