Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the new DOJ, National Security Division’s Export Controls and Sanctions Enforcement Policy for Business Organizations.

Some of the highlights include:

  • Why is there no declination available?
  • What aggravating factors are different between this policy and the FCPA policy?
  • What is an effective compliance program under this Policy and the OFAC Compliance Framework?
  • Who do you self-disclose to first if you uncover a trade sanctions violation?
  • Is this policy coordinated with other cooperation agreements?
  • What are the lessons learned for a corporate compliance program?
  • What does all this mean for compliance professionals going forward?


Matt’s blog post Cooperation for Sanctions Violations in Radical Compliance.