The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions

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Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify the authorities and agencies involved in trade law and the various mechanisms the regulators use to make rules and enforce them.

As trade law rapidly evolves to keep pace with geopolitical developments and challenges, See more +

Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify the authorities and agencies involved in trade law and the various mechanisms the regulators use to make rules and enforce them.

As trade law rapidly evolves to keep pace with geopolitical developments and challenges, corporate leaders and their compliance teams have the task of managing risks that are sometimes difficult to spot, especially as they involve multiple layers of the global supply chain. Our conversation stresses the necessity of diligence and knowing your customers and vendors, as well as exploring what a “reasonable, risk-based” compliance program looks like in practice.

We also discuss a key change in the statute of limitations—from five years to ten—in connection with the Office of Foreign Assets Control (OFAC) sanctions enforcement. This expansion of the lookback period has implications not just for compliance programs but could also complicate corporate transactions and the due diligence process.

We conclude our discussion by addressing how the evolving trade law regime impacts smaller enterprises that might have difficulty scaling the compliance function to manage trade-based risk. These enterprises face heightened risk as they are often targeted by bad actors seeking to evade sanctions via transshipment or some other means. See less -

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