Christina Clark, a former trial attorney in the U.S. Department of Justice's (DOJ) National Security Division (NSD), discusses Robert Bosch GmbH's (Bosch) recent settlements with the NSD – NSD's first declination under the DOJ's Corporate Enforcement Policy (CEP) – and the U.S. Department of Commerce's Bureau of Industry and Security (BIS). Both actions were based on allegations that Bosch violated the Export Administration Regulations' Foreign Direct Product Rule when Bosch's non-U.S. subsidiaries exported products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd., and its affiliates on the BIS Entity List. In the NSD declination, Bosch received credit for its early, voluntary self-disclosure to the DOJ. When misconduct is identified, companies should make a "determination of whether a voluntary self-disclosure is in the company's best interest," Clark said. However, she pointed out that companies need to understand that cooperation is an iterative process and that "[t]here may be costs in the short term to continuing to comply with DOJ requests for interviews or documents, but the benefits are potentially great in the long term." If seeking a declination under the CEP, companies should not wait for the DOJ to say what actions they should be taking to fix problems, Clark suggested. They "should be proactively implementing changes during the course of the investigation once the issues are identified and they have identified where the company shortcomings are."