Episode 222 -- Managing Third-Party Sanctions Risks

Economic sanctions enforcement is a fast-rising risk for global companies. For many years, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) focused primarily on financial institutions. Over the last ten years, OFAC has stretched its enforcement eyes towards software, manufacturing, telecommunications and technology companies.

With this growth in sanctions enforcement, OFAC has embraced an aggressive view of third-party risks. Like the FCPA, under OFAC’s regime, third parties are not permitted to do what the primary company cannot do. As a result, we have witnessed a steady increase in OFAC enforcement actions against global companies for failing to ensure compliance by third-party agents, distributors and other intermediaries.

In this Episode, Michael Volkov takes a deep dive into third party sanctions risks and strategies to mitigate such risks.