exportervsdssurvey

Couldn't confirm presence of Flash 8 or higher because JavaScript was disabled.Get FlashI really do have Flash installed.ul{margin-top:0px;margin-bottom:0px;list-style-type:none;padding-left:20px;}Voluntary Self-Disclosures (Export) Survey

We need your help. There is a big controversy within the trade community on whether filing Voluntary Self-Disclosures (VSDs) is a good idea. Your answers will help shed light on the controversy. We will report our findings and may include your written answers in next month's newsletter to help exporters decide their VSD policies and procedures.

You may remain anonymous.

Please proceed to question one.1. How would you describe yourself or your company?
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[ ] a. a. Experienced high volume/value exporter.

[ ] b. b. Novice high volume/value exporter.

[ ] c. c. Experienced mid-sized/volume/value exporter.

[ ] d. d. Novice mid-sized/volume/value exporter.

[ ] e. e. Experienced small-sized/volume/value exporter.

[ ] f. f. Novice small-sized/volume/value exporter.

[ ] g. g. Consultant or third-party logistics or transportation provider.

[ ] h. h. Oher. Please feel free to explain your answer on the final slide.

2. Have you or your company ever filed a voluntary self-disclosure for an export violation?
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[ ] a. a. Yes. Within the past year.

[ ] b. b. Yes. 2-3 years ago.

[ ] c. c. Yes. 3-5 years ago.

[ ] d. d. Yes. 5-10 years ago.

[ ] e. e. Yes. Over 10 years ago.

[ ] f. f. No. But we are considering filing one.

[ ] g. g. No. Never have and we are not considering filing one.

[ ] h. h. Other. Please feel free to explain your answer on the final slide.

3. What is your formal policy on VSDs for export violations?
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[ ] a. a. We have a formal written policy that we follow closely.

[ ] b. b. We do not have a formal written policy, but we have a formal procedure we follow closely regarding VSDs.

[ ] c. c. Ad hoc.

[ ] d. d. Other. Please feel free to explain your answer on the final slide.

4. If you filed a VSD, what was your experience?
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[ ] a. a. We got the mitigation that we wanted and the process was relatively painless.

[ ] b. b. We got the mitigation we wanted, but the process was painful and expensive.

[ ] c. c. We got some mitigation and the process was not awful.

[ ] d. d. We got little or no mitigation and the process was painful and expensive.

[ ] e. e. We're in the middle of a VSDs.

[ ] f. f. Other. Please feel free to explain on the final slide.

5. Did you audit your export transactions to prepare for the VSD?
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[ ] a. a. Yes. We audited our records before and after the VSD violation, but it was easy to do this.

[ ] b. b. Yes. We audited our records before and after the VSD violation, and it was difficult to do this.

[ ] c. c. No. We did not audit our records, but merely focused on the transactions in the VSD.

[ ] d. d. Other. Please feel free to explain your answer on the final slide.

6. How did you file your VSD?
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[ ] a. a. We filed an initial, general VSD, and followed up with a more complete version.

[ ] b. b. We filed everything at one time.

[ ] c. c. We reported the violation verbally to the Government and did not file a written VSD.

[ ] d. d. We reported the violation verbally, and then followed up with a written VSD.

[ ] e. e. Other. Please feel free to explain your answer on the final slide.

7. When we filed our VSD, the following happened.
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[ ] a. a. The Government liked our VSD and did not try to exclude certain violations.

[ ] b. b. The Government argued that either it had already started a formal investigation before we filed our VSD or that our VSD did not include all the violatlons uncovered.

[ ] c. c. Other. Please explain your answer in the final slide.

8. Please use this space to explain any of your answers.

Thank you for your answers.

GRVR Attorneys
214.720.7720
info@exportimportlaw.com

Main Business Address:

Park Place Center
Suite 300
2911 Turtle Creek Boulevard
Dallas, Texas 75219

Mailing Address:

Post Office Box 131587
Dallas, Texas 75313-1587

Dallas, Texas • Washington, DC • San Antonio, Texas • Mexico City, Mexico • Paris, France • São Paulo, Brazil

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