What is a voluntary disclosure?

A voluntary disclosure is notification to a federal agency that an export violation may have or has occurred.    If it is found that an export violation did occur, a voluntary disclosure will be seen as a mitigating factor (in most cases) when determining penalties and/or sanctions.

How to Disclose to the University?

If after reviewing the information provided on this website or any other export compliance resources and it is believed that an export violation may have occurred, please contact the Office of Research Compliance or use the University's Confidential Export Control Escalation Process. The Export Compliance Officer will work the faculty/staff to determine if a violation has occurred; and if required will coordinate with the Empowered Official to file a voluntary disclosure to the appropriate agency.

Federal Agency Views on Voluntary Disclosures

Department of State:

The Department of State strongly encourages the disclosure of information to the Directorate of Defense Trade Controls (DDTC) by persons, firms, or any organization that believes that they may have violated the International Traffic in Arms Regulations.  Voluntary self-disclosure may be considered a mitigating factor in determining the administrative penalties, if any, that can be imposed by the Department of State.

Department of Commerce:

The Department of Commerce encourages the disclosure of any violation of the Export Administration Regulations to the Office of Export Enforcement (OEE).Disclosure to OEE prior to the time that OEE, or any other agency of the US government, has learned the same, or substantially similar information, is considered a mitigating factor in determining what administrative actions, if any, will be sought by the OEE.

Department of Treasury

The Department of Treasury encourages the disclosure of any violation of Office of Foreign Assets Control (OFAC) regulations to OFAC.  Self-disclosure is considered a mitigating factor in civil penalty proceedings