Daniel McGillycuddy Quoted on New Guidance from DOJ on Export Controls and Sanctions Violations

November 16, 2016 – Morrison Cohen Partner Daniel McGillycuddy was quoted on new guidance from the National Security Division of the Department of Justice on requirements for companies seeking credit for voluntary self-disclosure of potential export controls and sanctions violations.  The article, “New Sanctions, Export Controls Guidance from DoJ”, appeared in Compliance Week on November 1, 2016.  Compliance and legal teams are facing harsher consequences pertaining to voluntary self-disclosures than was outlined in the Foreign Corrupt Practices Act (FCPA) Pilot Program:

“U.S. corporate entities and their counsel, when evaluating what previously may have been handled as a civil matter, now must consider whether the issues involved conduct by persons who knew their actions were not lawful,” says Daniel McGillycuddy, a partner at law firm Morrison & Cohen. “The guidance makes clear that more criminal investigations and, logically, prosecutions will be part of the changing landscape, and the guidance offers benefit to those who self-report similar to, though not as far-reaching, as the FCPA Pilot Program—clearly a crucial consideration for all experienced, sophisticated practitioners when advising on questions of cross-border and regulatory enforcement risks.”