On November 7, 2012, the Bureau of Industry and security (BIS) published in the Federal Register a proposed rule [Docket No. 120207107-2565-01] that would require that the final, comprehensive narrative account required in voluntary self-disclosures (VSDs) of violations of the Export Administration Regulations (EAR) be submitted to the Office of Export Enforcement within 180 days of the initial VSD notification. This proposed rule also would authorize the use of delivery services other than registered or…

On October 22, 2012, the Secretary of the Economy published in the Diario Oficial de la Federacion an Acuerdo which modifies the June 16, 2011 Acuerdo on export controls for conventional weapons, their parts and components, dual use goods, software and technology that could be diverted for the manufacture or proliferation of conventional weapons and those of mass destruction. The modifications included changes adopted in the 2012 Harmonized System, the Wassenar Agreement, the ML7 Munitions…

The United Kingdom’s Serious Fraud Office (SFO) has reviewed its policy on facilitation payments, business expenditure and corporate self-reporting and has revised its Questions and Answers page. The revisions were published because following his appointment, the Director of the SFO decided to review SFO policies and take forward recommendations made by the OECD Working Group on Bribery. The revisions have been published to: restate the SFO’s primary role as an investigator and prosecutor of serious…