US DOJ issues first-ever declination to prosecute a company that self-disclosed possible sanctions or export violations

US DoJ decided not to prosecute MillporeSigma due to factors such as voluntary self-disclosure of potential export control violations, full cooperation with investigators, and timely remediation of the alleged misconduct. These factors allowed law enforcement to identify culpable individuals, disrupt the scheme, seize illegal shipments, establish probable cause, and obtain guilty pleas from key participants…