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Voluntary Self-Disclosure to BIS or DDTC

Draft BIS and DDTC Voluntary Disclosures in Minutes

45 minutes with CaseMark

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2. Upload the files you want analyzed.

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Workflow

Voluntary Self-Disclosure to BIS or DDTC

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Workflow

Voluntary Self-Disclosure to BIS or DDTC

Overview

Preparing voluntary self-disclosures for export control violations is a high-stakes, time-intensive process requiring meticulous fact-gathering, precise legal analysis of EAR and ITAR regulations, and careful citation of CFR provisions. Trade compliance attorneys spend 6-8 hours manually researching regulatory requirements, analyzing transaction records, drafting detailed violation narratives, and ensuring submissions meet BIS or DDTC formatting standards—all while racing against disclosure deadlines.

Drafting a Voluntary Self-Disclosure to BIS or DDTC is a complex, high-stakes process requiring meticulous factual analysis, sophisticated legal reasoning, and strategic presentation. Manual preparation demands extensive document review, regulatory analysis, and careful drafting that can take weeks while the clock ticks on disclosure timing requirements.

CaseMark automates the VSD drafting process by analyzing your transaction records, extracting relevant facts, applying regulatory frameworks, and generating comprehensive disclosure documents. The platform ensures all required elements are addressed while maximizing mitigation benefits under voluntary disclosure policies.

How it works

  1. 1. Upload your documents

  2. 2. AI analyzes and extracts key information

  3. 3. Review and customize the generated content

  4. 4. Export in your preferred format (DOCX, PDF)

What you get

  • Identification of Disclosing Party

  • Description of Apparent Violations

  • Legal Analysis

  • Remedial Measures and Internal Investigation

  • Conclusion and Certification

What it handles

  • Identification of Disclosing Party

  • Description of Apparent Violations

  • Legal Analysis

  • Remedial Measures and Internal Investigation

  • Conclusion and Certification

Required documents

  • Transaction Records

    Commercial invoices, shipping documents, bills of lading, export licenses, and transaction histories related to the potential violation

    PDF, Excel, CSV

  • Internal Communications

    Email correspondence, internal memoranda, and communications regarding the transactions or compliance decisions

    PDF, MSG, EML, Word

  • Technical Specifications

    Product specifications, technical data sheets, and classification documentation for controlled items

    PDF, Word

Supporting documents

  • Compliance Program Documentation

    Existing compliance policies, procedures, training records, and audit reports

    PDF, Word

  • Prior Agency Correspondence

    Previous communications with BIS or DDTC, including licenses, registrations, or advisory opinions

    PDF, Word, MSG

  • Investigation Reports

    Internal investigation findings, root cause analysis, and forensic review results

    PDF, Word

Why teams use it

Generate complete BIS or DDTC voluntary disclosures in 12 minutes instead of 6+ hours

Automated citation of specific EAR (15 CFR) and ITAR (22 CFR) regulatory provisions with verification

Intelligent extraction of violation facts from investigation reports and transaction records

Real-time access to official BIS and DDTC submission requirements and best practices

Structured format compliance with regulatory agency expectations and templates

Questions

What is a Voluntary Self-Disclosure and when should I submit one?

A Voluntary Self-Disclosure (VSD) is a formal notification to BIS or DDTC regarding potential violations of export control laws. You should submit a VSD when you discover a possible violation of the EAR or ITAR before the government learns of it from other sources. Timely voluntary disclosure can significantly reduce penalties and demonstrate good faith compliance efforts.

How does CaseMark help with the VSD drafting process?

CaseMark analyzes your transaction documents, communications, and compliance records to extract relevant facts and organize them chronologically. It then applies the appropriate regulatory framework (EAR or ITAR) to generate a comprehensive disclosure document with proper legal analysis, remedial measures description, and all required certifications. The platform ensures your disclosure addresses all elements required for favorable consideration under voluntary disclosure policies.

What documents do I need to prepare a Voluntary Self-Disclosure?

You'll need transaction records (invoices, shipping documents, licenses), internal communications about the transactions, technical specifications for the controlled items, and any compliance program documentation. Optional but helpful materials include investigation reports, prior agency correspondence, and audit findings. CaseMark will analyze these documents to build the factual foundation for your disclosure.

How long does it take to draft a VSD with CaseMark?

CaseMark reduces the drafting process from 20-30 hours of manual work to approximately 45 minutes of automated processing, plus attorney review time. The platform handles document analysis, fact extraction, regulatory analysis, and initial drafting, allowing counsel to focus on strategic decisions and final quality review rather than time-consuming document preparation.

What are the benefits of making a Voluntary Self-Disclosure?

Voluntary disclosure can result in significantly reduced civil penalties, no denial of export privileges in egregious cases, and favorable consideration in enforcement proceedings. Both BIS and DDTC maintain policies that reward companies for self-reporting violations, conducting thorough investigations, and implementing meaningful remedial measures. A well-prepared VSD demonstrates compliance commitment and can preserve your ability to continue export activities.

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