General
Legal and compliance officers are used to adjustments and continuous improvement of their compliance programs. Building and maintaining an effective ethics and compliance program never ends -- it is a continuous process. To this end, in the environment of rapid change, compliance officers know how to remain steady and focus on
General
It may seem like a Herculean task -- but it can be done. I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks. One big reason -- geography is an important limiter on sanctions risks. The ability to
General
While OFAC's enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the "reason to know" and affirmative obligations to monitor resale and distribution of products to ultimate users does not appear to be unreasonable or