Facing the myriad third-party sanctions risks can be daunting.  Many global organizations rely on a network of third-party intermediaries that pose a variety of risks.  To mitigate those risks, companies have to implement practical steps tailored to the specific risks. Let’s start with some basic compliance requirements.  Initially, as part of the onboarding process and assignment of a sanctions risk category, global organizations have to...

United States businesses are experiencing a sanctions whipsaw.  Since 1979, the President has issued twenty-six Executive Orders restricting trade and commerce with Iran. The Iran Sanctions Program imposed strict prohibitions in a range of areas.  The Iran Sanctions Program and the Cuba Embargo are the two most restrict sanctions program implemented by the United States. All of this changed in January 2016 when the Joint...