ITAR and EAR Compliance Review and Investigations
Conducting Internal Audits and Evaluating Whether to Disclose Potential Violations to Mitigate Penalties
Recording of a 90-minute CLE webinar with Q&A
This CLE webinar will provide guidance for counsel to export companies on conducting reviews and investigations of ITAR and EAR compliance programs and determining whether and when to voluntarily disclose potential violations.
Outline
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Identifying a potential violation
- Internal audit
- Self-report
- Whistle-blower
- Government inquiry
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Commencing the investigation
- Document preservation
- Containment
- Investigation plan
- Stakeholder buy in
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Conducting the investigation
- Document review
- Interviews
- Site visits
- Targeted transaction audits or reviews
- Memorializing findings
-
Disclosure
- The decision of whether to disclose
- EAR considerations
- ITAR considerations
Benefits
The panel will review these and other key questions:
- What is the impact for an export control investigation of the source of the reported potential violation: employee report, internal audit, whistleblower's tip, or government investigation?
- What factors should a company consider in deciding whether and when to voluntarily disclose a potential violation to the government?
- How can counsel prepare clients to reduce noncompliance and mitigate penalties for export violations?
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Thaddeus R. McBride
Partner
Sheppard Mullin Richter & Hampton
Mr. McBride represents companies and individuals in international trade regulatory, compliance, investigative, and... | Read More
Mr. McBride represents companies and individuals in international trade regulatory, compliance, investigative, and enforcement matters involving U.S. economic sanctions and economic embargoes, U.S. export controls, FCPA, U.S. anti-boycott controls, U.S. customs and other import controls, anti-money laundering and other banking controls, and U.S. international trade enforcement and regulatory actions.
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Reid Whitten
Partner
Sheppard Mullin Richter & Hampton
Mr. Whitten's practice focuses on international trade compliance and investigation work. He advises clients on... | Read More
Mr. Whitten's practice focuses on international trade compliance and investigation work. He advises clients on detecting and deterring potential compliance issues with U.S. and international anti-corruption laws, export controls, and sanctions regulations. Mr. Whitten also advises on anti-dumping, anti-boycott and Foreign Agent Registration Act compliance issues.
CloseRandall H. Cook
Senior Atty.
Sikorsky Aircraft
He supervises a team of 10 attorneys and export control professionals with responsibility for export control... | Read More
He supervises a team of 10 attorneys and export control professionals with responsibility for export control investigations, disclosures, and compliance processes. Prior to joining Sikorsky, he served as an Assistant United States Attorney in New Jersey, investigating and prosecuting violations of U.S. export controls and sanctions, among other federal crimes.
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