Etymology, particularly the Greek or Latin roots of words, aids our understanding in much the same way as root cause analysis does. The Greek word for disclosure is transliterated to apokálypsi, or “apocalypse.” Nomen est omen. (The name is a sign.) This came to mind while reading the pronouncements proffered by various agencies this year—each of which influences voluntary disclosures of export control violations.
What once was a practical and efficient avenue for industry to inform the cognizant agencies of possible violations appears to have become a byway littered with mines, thanks to proposed and final rules issued by the Directorate of Defense Trade Controls (DDTC) and the Department of Defense (DoD). As it presently stands, contractors interacting with export-controlled information could face ruinous consequences if they act too reflexively in addressing cybersecurity incidents and events.
Trade Controls Proposed Rule
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