There’s a lot happening in export controls and sanctions right now.
U.S. regulators are becoming stricter. The EU is expanding and solidifying controls. India and China each have emerging export regimes. The use of sanctions is becoming more prevalent and nuanced. The issue today is that many companies’ business models are multinational, exposing them to a multitude of country- and region-specific export controls and sanctions rules and regulations that have to be managed. Companies must continually evolve their compliance programs to stay ahead of this ever-fluid scenario.
Export controls quickly become complex because they often require a technical understanding of sophisticated products as well as knowledge of all the parties in the transaction. Combined with the extraterritoriality of the U.S. and China regimes, export compliance professionals are often forced to manage, or at minimum be aware of, regulations they don’t fully understand. U.S. sanctions pose similar management challenges, as they prevent U.S. persons and entities from conducting business with a designated individual or entity anywhere in the world and can require a deep understanding of the related flows of goods and funds.
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