Torres Law in the US has produced a handbook which describes a voluntary self-disclosure (also known as voluntary disclosures or prior disclosures depending on the governing agency) as a narrative account with supporting documentation that describes violations or suspected violations of import or export regulations.  It says that most US government agencies permit companies to file an Initial Notification of the VSD before submitting the full VSD – and, in general, the Initial Notification serves as a notice to the regulatory and enforcement agencies of the general nature and extent of the potential violations.  The handbook considers why file a voluntary disclosure, and the risks of doing so, before explaining the steps in making one.  It then looks at the individual government agencies that may be involved, and the processes and considerations for each.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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