Overview
Export Compliance Manager quoted Meredith Rathbone in a February 2022 article titled "Russia-Ukraine: are you sanctions-ready?" As Russia postures to invade Ukraine, US and European leadership work to develop a punitive sanctions strategy. This article discusses what companies should be considering to prepare for the pending sanctions and controls.
To companies, Rathbone suggests that "If you haven’t mapped your supply chain completely, you should be doing that now." Additionally, Rathbone instructs export compliance teams to do the following:
- "Review business partners for services as well as parts and components
- Ensure business partner due diligence is robust
- Assess whether stronger de minimis or Foreign Direct Product rules would capture your products
- Look at your banks, financing flows, and loan agreements to spot risk points
- Double-check contracts have an exit clause in the case of sanctions or entity list designations, and consider Russian law implications"
The full article can be read at Export Compliance Manager (subscription required).
For additional information, watch the recording of "Possible Sanctions Against Russia: What You Need to Know"– a webinar hosted by Steptoe's Economic Sanctions team.
