Quarterly Trade Compliance Update – July 2023
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs.
Below is a summary of events this past quarter:
- Continued significant activity involving Russia and Belarus. There have been a number of additions to the SDN List, along with additional export controls including sweeping restrictions on industrial items.
- Publication of the Tri-Seal Compliance Note: Voluntary Self-Disclosure of Potential Violations, providing information regarding the procedures around reporting potential violations.
- Executive Order 14098 was issued imposing additional sanctions on Sudan.
- Publication of the Africa Gold Advisory, issuing warnings regarding African gold trade and malign actors, including Russia’s notorious Wagner Group.
- Please remember to file your Annual Report of Blocked Property before the September deadline.
About the document:
This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each program.
This document can be especially useful for non-lawyers and non-compliance officers. Some of our clients distribute the document to the sales and operations teams, or hang it with other legal and compliance material somewhere in the office. Many front-line employees need to know enough about sanctions to identify red flags and then engage legal and compliance as needed. We’ve unfortunately seen unwitting violations due to a lack of education or a lack of reference materials.