How Anti-Corruption Compliance Can Springboard Sanctions Compliance

As economic sanctions regimes move from broad embargoes to more focused measures, it is critical for businesses to determine whether a particular person or entity is subject to sanctions. Because there is often considerable overlap between FCPA and sanctions risks, anti-corruption compliance measures can often be leveraged for sanctions compliance. During a program at SCCE’s Annual Compliance and Ethics Institute, Ryan P. Fayhee, a partner at Baker & McKenzie, Catherine L. Razzano, assistant general counsel and director of General Dynamics Corporation (speaking on her own and not the company’s behalf) and Anne-Marie Zell, a manager at TRACE International, Inc., discussed the current U.S. sanctions regime and provided advice on how to leverage FCPA compliance programs to facilitate sanctions compliance. Razzano also discussed how General Dynamics handled the imposition of Russian sanctions in 2014. See “Five Ways a Company Can Leverage Its Anti-Bribery Compliance Program to Facilitate Sanctions Compliance” (Sep. 14, 2016).

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