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Reducing Third-Party Trade Compliance Risks  

Author:  Peter Lichtenbaum.; Eric Sandberg-Zakian.

Source: Volume 51, Number 15, September 1 2018 , pp.187-190(4)

Review of Securities & Commodities Regulation

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The authors find that companies often overlook the risks posed by shortcomings in the trade compliance programs of their third-party business partners. In this article they describe two recent cases that illustrate such risks. They then suggest remedial steps in initial and follow-up due diligence, entering or renewing contracts, and responding to red flags.

Keywords: Epsilon Electronics, Inc. v. United States Department of the Treasury, Office of Foreign Assets Control; DENTSPLY SIRONA Inc.

Affiliations:  1: Covington & Burling LLP; 2: Covington & Burling LLP.

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