Compliance With International Sanctions: “Facilitation” and “Circumvention” – Considerations for EU Citizens and US Nationals Wherever They Are Located

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Restrictions on where your company can do business, prohibitions on those entities and individuals with whom you can engage, and wider measures relating to export and investment activity implemented under EU and US sanctions legislation trigger a wide range of offences. Companies on both sides of the Atlantic, and European and US, nationals employed or acting on behalf of companies outside of the EU and US need to consider and comply with these measures in order to manage both corporate and individual personal liabilities. Given the heightened sensitivity following:

- the recent expansion of sanctions across a range of destinations and activities; and

- the headlines regarding prosecutions, fines and punitive settlements for failure to implement robust risk management procedures....

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