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Export violations occur and Excelerate's experience in support customers with Voluntary Disclosures will obtain the positive results you want to achieve.
There are two types of disclosures related to export violations: Directed – which is when the U.S. export authorities come to you with the violation; or Voluntary – when you report the violation on your own. Although uncomfortable, reporting your own export violation is much better than having the authorities come knocking on your door.
Responding appropriately with a Voluntary Disclosure is important when a violation occurs. Excelerate will provide an experience proven approach to supporting the Voluntary Disclosure Process. We will first provide a questionnaire to gather the necessary data then work with you in drafting the appropriate submission to DTC or BIS. Excelerate is with you every step of the way...
Elements to a Voluntary Disclosure
A Voluntary Disclosure is a document that precisely describes the violation and what compliance changes will be made to stop it from happening again. Critical elements associated with the Voluntary Disclosure include:
- A precise description content and timeline of the violation.
- Names and addresses of all organizations involved.
- Any associated license or agreement approvals.
- US Munitions List (USML) or Commerce Control List (CCL) categories invovled.
- Descriptions, quantities, pricing, etc. of any invovled articles or technical data.
- A statement associated with the percieved severity of the violation. Would it be considered minor or significant, intentional or inadvertant,...
- What changes to organization export compliance policies and procedures will be made to mitigate the chance of violation reoccuring.