Partner, Eric McClafferty's
presentation, "The Role of Internal Investigations and Voluntary Disclosures in Minimizing Risk and Mitigating Penalties and Enforcement Actions" reviewed export enforcement issues, including how investigating potential compliance violations and submitting voluntary disclosures has an important role in mitigating penalties. Subjects included: How do DOE, NRC and BIS approaches differ in regards to enforcement and voluntary disclosures? How should an internal investigation be conducted? How do you determine when to file a voluntary disclosure, and how much to disclose? When should you seek outside counsel, and how should corporate defense be balanced against cooperation? This presentation discussed how to successfully implement remedial measures and prevent future violations.
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