Historically, corporate sanctions compliance programs have tended to focus primarily on ensuring that products and services are not sold or diverted to prohibited customers or sanctioned territories. There has often been less focus on the entirety of the supply chain, particularly the significant sanctions compliance risks that can arise upstream in the context of suppliers and vendors. Over the past few years, there has been a shift, with many companies now paying closer attention to…
When companies and compliance departments think about US sanctions and export control risks, they often focus on sales to customers and exports/reexports from one country to another. In that context, the attention is typically on confirming that a customer and other parties involved in a sale and shipment are not restricted parties and that the transfer of a product is authorized under applicable export-control regulations. This is only half the story. Companies can have similar…