On March 30, 2026, the Department of Justice’s National Security Division (NSD) issued a press release reinforcing that companies seeking to voluntarily self-disclose criminal violations of national security laws—including export control and sanctions laws, and foreign investment and foreign telecommunication laws—should report those disclosures directly to NSD.[1] The announcement follows the Department of Justice’s (DOJ) March 10, 2026 release of its first-ever Department-wide Corporate Enforcement Policy (CEP), which established a unified framework for how DOJ evaluates corporate voluntary self-disclosures, cooperation, and remediation across all DOJ components, except the Antitrust Division.[2]
Continue Reading NSD Flags Its Role as the Front Door for National Security-Related Voluntary Self-Disclosures Under the New Department-Wide Corporate Enforcement Policy
DOJ National Security Division Issues Second Declination Under Corporate Enforcement Policy
On April 30, 2025, the Department of Justice’s (“DOJ”) National Security Division (“NSD”), alongside the U.S. Attorney’s Office for the Northern District of California, announced a declination to prosecute Universities Space Research Association (“USRA”) for criminal export control violations committed by a former employee.[1] This marks only the second declination issued by NSD under its Enforcement Policy for Business Organizations (the “Policy”), following voluntary self-disclosure.
Continue Reading DOJ National Security Division Issues Second Declination Under Corporate Enforcement PolicyDOJ New Safe Harbor Policy for Voluntary Self-Disclosures in M&A
In recent months, U.S. Department of Justice (“DOJ”) leadership reiterated their intention to continue focusing on prosecuting crime by companies and responsible individuals, in particular in areas relating to national security. To this end, DOJ recently has amended or formalized policies intended to incentivize companies to report criminal misconduct, cooperate in DOJ’s criminal investigations and remediate.[1] In line with that trend and as previewed last month by the Principal Associate Deputy Attorney General,[2] the DOJ officially announced its New Safe Harbor Policy for Voluntary Self-Disclosures Made in Connection with Mergers and Acquisitions (“M&A Safe Harbor”).[3]
Continue Reading DOJ New Safe Harbor Policy for Voluntary Self-Disclosures in M&A