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Navigating US Extraterritorial Sanctions and Export Control Risks with a Nimble Compliance Program

Dealing with the compliance challenges presented by near daily new US sanctions and export controls requires a risk-based compliance program that addresses rapid change and mitigates increasing global enforcement risk, while still being practical and business friendly.

Most general counsels will be familiar, at least to some degree, with the increasing risks presented by the extraterritorial application of US sanctions and export controls. Frequently changes, in both scope of territories and parties caught and the types of restrictions, coupled with possible severe consequences (blacklisting, monetary penalties), mean that compliance programs must be nimble, addressing key risks while being practical and business friendly. A quick guide published on the website of the Dutch general counsel organization discusses questions relating to key risks assessments and provides some answers.

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