■■ ■ Know your controls. The term
“export control” refers to
the regulations imposed by
countries on what products
may be exported, where they
can be exported, and for what
purpose they can be exported.
■■ ■Task of multitasking. In-house
counsel will need to review the
rules, regulations, and procedures
for all agencies that regulate DOJ
export controls. The US State
Department, the US Commerce
Department, and the US Treasury
Department are all responsible
for enforcing these policies.
■■ ■ Credit for cooperation. In order
for a company to receive credit
for disclosing an export control
violation, it must be voluntary,
complete, timely, and made to the
Counterintelligence and Export
Controls Section of the DOJ.
■■ ■ Aggravating circumstances.
There are certain aggravating
circumstances that will reflect
unfavorably on a company
regardless of whether they
choose to self-report criminal
conduct to the DOJ or not.