Reporting Voluntary Self-Disclosures of Violations of National Security Laws Under the Department-wide Corporate Enforcement Policy

# DOJ Announces Corporate Enforcement Policy for National Security Violations

The Department of Justice's National Security Division released its first-ever Department-wide Corporate Enforcement Policy on March 10, 2026, establishing uniform standards for prosecuting white-collar crimes involving national security violations. The policy aims to promote predictability and fairness in how the federal government pursues cases related to unlawful exports of sensitive technologies and commodities, as well as unauthorized transactions with sanctioned countries and entities.

Under the new policy, companies that voluntarily disclose violations, cooperate with investigations, and implement timely remediation measures will generally avoid prosecution, absent aggravating circumstances. The policy requires disclosures be made to the appropriate Justice Department component, with all resolutions requiring approval from the relevant Assistant Attorney General. The framework covers violations of major export control and sanctions laws, including the Arms Export Control Act, Export Control Reform Act, and International Emergency Economic Powers Act.

The DOJ stated the policy incentivizes corporate self-reporting while still permitting prosecutions when appropriate. Officials emphasized the approach allows the government to pursue culpable individuals, secure justice for victims, and deter white-collar crime without unduly burdening American businesses engaged in legitimate commerce.