On December 20, 2011, partner Eric McClafferty presented at the Export Practitioner and Washington Tariff & Trade Letter Live Audio-Conference Briefing. The audio-conference, "Export Enforcement Case Study: Flowserve's $3 Million Global Settlement," discussed the dilemma that Flowserve faced when its headquarters learned that several of its facilities may have violated the Export Administration Regulations and sanctions imposed by the Office of Foreign Assets Control. The company made a voluntary self-disclosure and paid $3 million in civil penalties, an amount that was significantly less than might have been assessed. Mr. McClafferty discussed how Flowserve handled this export enforcement case and discussed what can be learned from Flowserve's experience.
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