Prepare for US Gov't Sanctions Compliance 'Inquiries,' Law Firm Says
Companies should be prepared for more “swift and persistent changes” to U.S. sanctions and export control regulations as the Biden administration continues to impose restrictions on Russia for its invasion of Ukraine, Barnes & Thornburg said in an April 4 client alert. The firm also said companies should prepare for U.S. government “inquiries into their transactions” even if they aren’t doing business in Russia or Belarus. “[T]hird-party intermediary risks are global,” it said. The Bureau of Industry and Society is one agency ramping up outreach to exporters amid a rise in new restrictions against Russia and China (see 2303240060).
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Barnes & Thornburg encouraged businesses to review and update their compliance policies ahead of outreach by the government. This may include bolstering their sanctions screening, improving due diligence practices for business partners, staying “on top” of end-use and end-user declarations and shoring up “supplier certifications to reduce exposure” in transactions. “In short,” the firm said, “knowing your supply and distribution chains to avoid or mitigate disruptions as the rules evolve is key.”