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    Schenker Trade Compliance Notice: Voluntary Self-Disclosure for Export Compliance

    A robust compliance program is essential to maintain conformity with U.S. sanctions, export controls, and other national security laws, including recent updates to certain policies. The program should also give clear guidance on how to escalate potential violations and other compliance concerns internally.

    The Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) on July 26 issued a joint compliance note focusing on voluntary self-disclosure policies.

    Adhering to export compliance programs is key to prevention of violations. Schenker’s policies and processes help reduce the risk of potential export violations, and it is critical for exporters to alert Schenker to unique handling requirements.

    In the event a potential violation is discovered, below are some of the benefits associated with submitting a voluntary self-disclosure.

    1. Compliance with regulations: Discovering and reporting non-compliance through voluntary self-disclosure can demonstrate an organization's commitment to adhering to these regulations and mitigating potential penalties or legal consequences.

    2. Building trust and credibility: By voluntarily self-disclosing any non-compliance issues, an organization demonstrates transparency and a commitment to doing the right thing. This can help build trust and credibility with internal stakeholders, such as employees and shareholders, as well as external parties like customers, suppliers, and regulatory authorities.

    3. Mitigating penalties: In some cases, regulatory authorities may reduce penalties or provide leniency for organizations that self-disclose non-compliance issues. By promptly reporting any violations and taking remedial actions, an organization can show its willingness to rectify the situation, potentially leading to reduced penalties or other favorable outcomes.

    4. Preserving reputation: Self-disclosing non-compliance issues can help an organization protect its reputation. Acting proactively rather than waiting for issues to be discovered or reported by others helps to limit damage to the organization's image and can demonstrate a commitment to ethical conduct and responsible business practices.

    5. Internal improvement: Self-disclosure provides an opportunity for organizations to identify and address any gaps or weaknesses in their compliance programs, internal controls, or operational processes. It allows for a comprehensive analysis of the root causes of non-compliance and presents an opportunity for implementing corrective measures to prevent similar incidents from recurring.

    Overall, a voluntary self-disclosure promotes a culture of accountability, transparency, and proactive risk management, which are essential for long-term organizational success. We appreciate your continued support as a valued customer. Should you require further information or clarification, please reach out to your Schenker contact

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    Voluntary Self-Disclosure

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