2006/02/26
By: John Black
Recently Washington insiders have been talking about the VD to penalty ratio. In our context, that means that of the approximately 400 voluntary disclosures DDTC processed over the last year, DDTC imposed a fine in only 4 cases. Wow.
Of course, submitting voluntary disclosures are not a free pass. But, VD experts often comment that exporters might be more likely to get a fine for a VD related to an EAR violation than for an ITAR VD. The BIS website has plenty of announcements about companies who got fined after making an EAR VD.
Interesting…