Supply Chain and Sanctions Compliance (Part III of IV)
While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale and distribution of products to ultimate users does not appear to be unreasonable or impractical. In terms of best practices, these are issues that need to be addressed. The supply chain and third-party risk...