In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated prosecutions for sanctions and export control violations.  The last piece in launching this new effort was the announcement of a joint voluntary disclosure program to ensure alignment among the agencies for civil and criminal enforcement of such violations.

The Joint Compliance Note (“JCN”) urges companies to disclose potential offenses and emphasized the importance of companies implementing “robust” compliance programs.  The JCN outlines in one document all of the various changes instituted by DOJ, Commerce’s Bureau of Industry and Security (“BIS”) and Treasury’s Office of Foreign Asset Control (“OFAC”) in voluntary disclosure and enforcement policies and procedures.The JCN emphasized the importance of prompt disclosure in situations that may implicate national security issues.