News & Analysis as of

Suppliers Supply Chain Office of Foreign Assets Control (OFAC)

The Volkov Law Group

Supply Chain Sanctions Liability — The Importance of Supply Chain Audits (Part III of IV)

The Volkov Law Group on

Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime.  OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more

The Volkov Law Group

Supply Chain and Sanctions Compliance (Part III of IV)

The Volkov Law Group on

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...more

Foley & Lardner LLP

Navigating Global Trade Regulations: Minimizing Supply Chain Risks When Importing from Abroad

Foley & Lardner LLP on

Regulators have sent numerous messages that companies who source from abroad need to subject their entire supply chain to extensive due diligence, based on state-of-the-art compliance measures to minimize supply chain risks....more

Pillsbury - Global Trade & Sanctions Law

U.S. Expands WROs in Xinjiang, Targeting Major Cotton Producer with Implications for Global Supply Chains

On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more

The Volkov Law Group

OFAC Sanctions Compliance: 2019 a Game-Changing Year (Part II of II)

The Volkov Law Group on

Moving on, 2019 was a big year in OFAC compliance. The Sanctions Compliance Guidance was a major change in sanctions compliance. OFAC has set high expectations for compliance. Whether companies have received and responded to...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

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