Deborah Curtis Quoted in Global Investigations Review on DOJ’s USRA Declination

Deborah Curtis, co-chair of the firm’s White Collar Defense & Investigations practice and a former National Security Division prosecutor at the U.S. Department of Justice (DOJ), was quoted in the Global Investigations Review article, “USRA declination an ‘easy call’ that doesn’t break new ground.” The article covers the DOJ’s decision to decline prosecution of the University Space Research Association (USRA) following its voluntary disclosure of export control violations involving restricted flight software sent to a blacklisted Chinese university.

Curtis described the decision as “somewhat of an easy call,” pointing to the limited national security risk, clear individual culpability, and USRA’s prompt remedial actions. She noted that the case ultimately did not shed new light on how companies might secure declinations in more complex matters. Curtis and other white-collar attorneys said the case illustrates the DOJ’s willingness to issue declinations in clear-cut cases. However, how the Trump administration will approach more complex self-disclosures remains unclear.

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