On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled "Obligations of Foreign-Based Persons to Comply .
A common approach in dealing with potential violations of the US export control laws is to undertake a voluntary disclosure to the regulators and thereby benefit from long-standing.
The Memo signals a significant shift in BIS enforcement policy, as previously companies that filed VSDs could receive partial or total mitigation of civil penalties, but were not penalized if they failed to voluntarily come forward.
In recent years, Singapore has become a significant hub for international commerce. According to the U.S. International Trade Administration, the U.S. was Singapore’s fourth largest.