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DOJ National Security Division’s Enforcement Policy, Explained

A TRACE WHITE PAPER

TRACE WHITE PAPER

 

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In December 2019, the U.S. Department of Justice National Security Division (NSD) announced substantial revisions to its export controls and sanctions enforcement policy. The DOJ’s latest addition to its suite of policy tools is helpful in moving toward increased transparency in its decision-making processes. In this white paper, Paul Hastings LLP reviews key points of the policy, including:

  • the fundamentals of the NSD policy;
  • how the revised NSD policy and the Corporate Enforcement Policy overlap and diverge; and
  • remaining questions about the implications of the revisions to the NSD policy.

This is the second in a series of white papers from TRACE on sanctions. The first in the series, "Does Your Sanctions Compliance Program Align with OFAC’s 2019 Compliance Framework?", is available on the TRACE Publications page.

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