Managing global telecom supply chains – What telecommunications companies need to know about trade control laws

Hogan Lovells
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Maintaining a global supply chain brings its share of commercial, financial, and regulatory risks. Increasingly, telecommunications companies with global operations and suppliers are finding that U.S. trade control laws affect their operations. For instance, telecommunications companies can inadvertently breach export control or economic sanctions laws when critical suppliers are designated on U.S. or non-U.S. government restricted parties lists, engage in prohibited

transactions with sanctioned countries, or re-export U.S. origin items to prohibited destinations, end users, or end uses. In an interconnected world, even companies that primarily provide products and services within the U.S. can be exposed under trade control laws if they have a global supply chain. This article highlights the three areas of U.S. trade control laws that can affect the operations of U.S. telecommunications companies: export controls, economic sanctions, and anti-boycott restrictions. With U.S. and non-U.S. trade control laws constantly evolving as U.S. foreign and national security policies react to global developments, U.S. telecommunications companies need to remain alert to potential risks in their global activities and implement robust compliance programs to be prepared for sudden shifts in U.S. policy and/or legal requirements.

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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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