Compliance Convergence: Export Control


Previously we have written about Compliance Convergence, which noted Compliance Expert Howard Sklar, the author of Open Air Blog, has termed as “the merging of control programs such as anti-bribery and anti-corruption, with anti-money laundering, and export control.”, in regard to the Foreign Corrupt Practices Act (FCPA) and touched on briefly with regards to anti-money laundering laws and regulations. Today we will turn our attention to Howard’s third prong in Compliance Convergence, that of Export Control.

Generally speaking, a Company must comply with all applicable export control laws in the country of origin of the products including, in some instances, the components contained within the products and technologies they are exporting; and all applicable international sanctions that may not be directly addressed in national law (e.g., United Nations sanctions programs). Witness the recent sanctions entered into by the US, UN and EU regarding trade with Libya.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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