By Robert J. Ward, Jr., VP, Global Compliance, Houston International Business Corp.
Has your company ever faced a penalty assessment for a violation of U.S. Sanctions law? The largest Sanctions Law penalty exceeds the largest FCPA penalty by a factor of 10x! Having to pay a Sanctions Law penalty will cause the company to be reported in the Federal Register. The New York clearing house banks for U.S. Dollar wire-transfers will then impose significant due diligence burdens on the offending company before processing payment transactions – a serious impediment to cash flow.
The Federal Government restricts companies from doing business with embargoed countries as well as with blacklisted parties. Having the proper screening software in place that is right for your business model is critical. Don’t be caught flat-footed with this ever-changing area of the law! You will come away with key recent enforcement examples (with the ZTE case providing ample guidance on what not to do!) as well as key steps to take to prevent violations including best practices for policies/procedures, screening, due diligence and training.