Compliance and Self-Protection in an Uncertain Sanctions Environment

The United States economic sanctions regime is experiencing a period of turbulence, with major changes occurring in sanctions programs (and the recent restructuring of the state department sanctions office) affecting trade involving several nations that have a significant presence in the world economy. In a guest article, Scott Balber, Jonathan Cross and Jared Stein of Herbert Smith Freehills explain how these developments underscore the importance of managing sanctions risk which may arise from future changes in U.S. law, both by establishing appropriate exit procedures should sanctions require the termination of existing arrangements, and by conducting appropriate political risk assessment and counterparty due diligence to identify and mitigate the potential for sanctions-related business disruption. See “Five Ways a Company Can Leverage Its Anti-Bribery Compliance Program to Facilitate Sanctions Compliance” (Sep. 14, 2016).

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