Draft Initial Voluntary Self

---
name: its-draft-bis-initial-vsd
task_id: international-trade-sanctions/draft-initial-voluntary-self
description: Drafts an initial voluntary self-disclosure letter to the relevant export-enforcement authority and an internal cover memo that follow the required identification elements, classify each product and transaction at the appropriate specificity, separate distinct regulatory theories where applicable, and flag any parallel sanctions analysis or follow-on filing considerations where warranted.
activates_for: [planner, solver, checker]
---

# Skill: Draft Initial Voluntary Self-Disclosure to BIS

## 1. Subject-matter triage

- Treat this as a dual-output drafting task: the disclosure letter is the primary deliverable, and the internal memo is secondary.
- Draft the disclosure letter first, then the internal memo after the letter content is complete.
- If the facts suggest both export-control and sanctions exposure, preserve both tracks; do not force a single legal theory.
- If multiple products, counterparties, shipment groups, or time periods are involved, enumerate them before analysis and keep each row distinct in the draft.

## 2. Failure modes the skill is correcting

- Identifying the conduct only at a generic product level instead of pairing each product name with the applicable export-control classification and transaction context.
- Collapsing multiple shipments, counterparties, or periods into one aggregate narrative that obscures the scope of exposure.
- Blending separate regulatory theories together when the same facts may implicate more than one restriction regime.
- Drafting a disclosure that sounds complete narratively but omits the required identification, chronology, or remediation elements.
- Omitting the internal memo’s job of flagging open issues, parallel filing needs, and individual exposure before submission.
- Making legal assertions without tying them to the governing export-control or sanctions authority.
- Failing to preserve a clear drafting hierarchy: operative disclosure first, memo second.

## 3. Legal frameworks / domain conventions that apply

- Initial voluntary self-disclosure practice under BIS Office of Export Enforcement expects a formal filing that identifies the submitting entity, the nature of the apparent violations, the product classifications, the relevant parties, the dates, the transaction values, how the issue was discovered, what was done internally, and what remediation followed.
- Export-control analysis should tie each product to its specific classification and transaction facts; trade-name-only descriptions or classification-only descriptions are incomplete.
- Where the conduct touches restricted destinations, restricted parties, military or end-use/end-user concerns, treat each legal theory separately and identify the governing rule for each.
- Where sanctions exposure may exist alongside export-control exposure, the internal memo should flag the need for a parallel sanctions review and consider whether a separate disclosure track is warranted.
- The draft should reflect the applicable BIS-oriented licensing and enforcement framework rather than generic compliance language; state the legal basis for restriction when it matters to the analysis.
- Any legal proposition stated in the letter or memo should be anchored to a controlling authority by name and citation format appropriate to the source materials or generally recognized practice.

## 4. Analytical scaffolds

1. Open with the addressee, subject line, and a concise statement that the submission is intended as an initial voluntary self-disclosure.
2. Identify the submitting company with legal name, formation jurisdiction, and headquarters address.
3. Enumerate each product or product group in scope, then for each one pair the commercial name with the relevant export-control classification and transaction context.
4. Enumerate each counterparty, destination, or shipment cluster separately; for each, state the value, shipment count, and date range without collapsing across distinct exposure buckets.
5. For each distinct legal theory, analyze it on its own terms: destination restriction, restricted party, end use, end user, or other applicable basis.
6. State the discovery date, how the issue was found, who escalated it internally, and whether outside counsel or other advisors were engaged.
7. Summarize the remedial steps already taken and any compliance enhancements implemented or planned.
8. In the internal memo, identify unresolved factual questions, parallel sanctions issues, individual officer or employee exposure issues, and any filing sequencing questions.
9. If the source facts point to additional follow-on disclosures or agency notifications, note them as open issues rather than assuming they are unnecessary.

## 5. Vertical / structural / temporal relationships

- Keep the chronology explicit: pre-discovery conduct, discovery, containment, investigation, remediation, and filing decision.
- Keep the legal tracks separate when one factual stream creates different obligations under different regimes.
- Keep the transactional mapping vertical: product → classification → counterparty/destination → shipment/date/value → legal theory → consequence.
- Keep memo findings tethered to the draft letter so the internal assessment can test whether the filing is complete before submission.
- If the source set contains more than one period, customer, product, or theory, use separate subsections or rows so the reader can audit scope without inference.

## 6. Output structure conventions

- Produce two discrete documents: the initial voluntary self-disclosure letter and the internal cover memo.
- Use a formal regulatory letter style for the disclosure, with a clear heading, submission purpose, factual narrative, issue-specific analysis, and remediation section.
- Include compact tables where helpful for products, counterparties, dates, values, and classifications, but do not bury the narrative in tables alone.
- The internal memo should read as a privileged internal advisory document, identifying open risks, parallel filing considerations, and decision points before submission.
- End the memo with an explicit action-oriented recommendations section naming the next step, the responsible role, and the urgency tied to the filing timeline.