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White Collar + Fraud + Investigations + Compliance

  • Posts by Angela I. Gamalski
    Posts by Angela I. Gamalski

    Angela Gamalski is a partner in the firm’s Regulatory Department. She advises firm clients regarding a variety of trade and international regulatory and transactional matters.  Her areas of focus include:

    • Anti-Money Laundering ...

On July 26, 2023, the U.S. Department of Justice, National Security Division (“DOJ NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued the second-ever Tri-Seal Compliance Note (the “Note”). This Note discusses Voluntary Self-Disclosure of Potential Violations and discusses each agency’s aligned expectations for companies that discover potential violations of any administrative or criminal violations of sanctions and export controls, including expectations for prompt disclosure and remediation of such violations. The agencies collectively stress the important role that private sector businesses play in identifying threats from malicious actors and foreign adversaries seeking to subvert the U.S. financial system or access sensitive U.S. technologies or goods.

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