DOJ Applies New Policy, Declines Prosecution in Export Control Matter

The U.S. Department of Justice's National Security Division has issued its first non-prosecution decision under a recently updated corporate enforcement policy. This decision involved Robert Bosch GmbH, which avoided prosecution for potential export control violations concerning a sanctioned Chinese entity. The company received the declination by voluntarily disclosing the issue, conducting an internal investigation, and agreeing to pay $11.4 million in disgorgement. This case highlights the new policy's emphasis on self-reporting and remediation.