Supply Chain Sanctions Liability — The Importance of Supply Chain Audits (Part III of IV)
Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime. OFAC has emphasized the importance of conducting supply chain risk assessments and audits. A supply chain audit (akin to UFLPA and conflict minerals) is essential to assess, monitor and manage risks. Even though parties are not in direct privity, a company that sources materials from a prohibited party or...