Global Trade Compliance Atlas

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120 121 122 123 124 125 126 127 128 129 130

§ 127.12

Voluntary disclosures

ITAR · Part 127

The mitigation path. A voluntary disclosure to DTCC of a suspected violation is a major mitigating factor in civil-penalty and debarment decisions — if it is timely, complete, and not made after the government has already asked. Immediate notification, a full narrative, a document production, and a corrective-action plan are the expected contents. A disclosure is not immunity and is not a license to continue the activity.

Notify DTCC quickly, then supplement. Waiting for a perfect internal investigation burns the “voluntary” in voluntary disclosure.
Continuing the unlicensed activity after discovery is a new, worse violation.

eCFR (primary) · § 127.12 LII (secondary, unofficial)

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In this atlas

§ 127.1 § 127.10 § 127.2 § 122.5