On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm and its affiliates following the firm’s voluntary disclosure of sanctions- and export control-related violations involving an entity the firm acquired in 2020.  The watershed announcement marks the first application of the voluntary self-disclosure safe harbor provision from the DOJ’s Mergers and Acquisitions Policy (“M&A Policy”) adopted in March 2024.