Five Ways to Use Existing Resources to Meet Sanctions and Export Control Compliance Needs

Over the past several years, there has been a steady drumbeat of statements from the DOJ, the Department of Treasury and the Department of Commerce, particularly the Bureau of Industry and Security, regarding the importance of sanctions and export control compliance. However, establishing and maintaining an effective compliance program in an area that until recently may have seemed lower risk can be daunting. Fortunately, when it comes to sanctions and export control compliance, companies with established anti-bribery and corruption and wider financial crime compliance programs may be further along than they realize. In a guest article, Joshua Drew, a member of Miller & Chevalier, and Laura Deegan, a counsel at the firm, discuss the current state of play regarding sanctions and export control enforcement, including the government’s developing priorities, and make five concrete suggestions on how to best stand up or strengthen an existing compliance program making efficient use of existing resources. See the Anti-Corruption Report’s two-part series on New Russia Restrictions: “Agency Cooperation and Industry Focus” (Mar. 13, 2024), and “International Cooperation and Risk Mitigation” (Mar. 27, 2024).

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