Jonathan Cross recently published "Managing Sanctions Risk Up and Down the Supply Chain" in the Anti-Corruption Report. The article looks at the importance of companies ensuring their sanctions compliance procedures address "supply-chain" risks, given the increase in actions brought by The US Treasury Department's Office of Foreign Assets Control (OFAC); where the subject was one or more steps removed from dealing with a U.S. sanctions target, and may have been unaware of the involvement of a sanctioned person or jurisdiction either upstream or downstream. Jonathan discusses four recent enforcement actions that shed light on how OFAC views sanctions risk both upstream and downstream in the supply chain and offers compliance strategies and approaches in light of these insights. To access the article, please click the link below.
ACR_Managing Sanctions Risk Up and Down the Supply Chain
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