Click here to read the full Client Advisory by Steptoe.
What can we learn from recent SDN designations by the US Office of Foreign Assets Control (OFAC) on multinationals such as subsidiaries of COSCO and Rosneft Trading S.A.?
OFAC has shown a willingness to impose, then lift, sanctions on major companies that play an important role in global supply chains, forcing counterparties to react fast and adapt. In this advisory, we comment on the types of companies OFAC may sanction, how long those sanctions may last, and whether impacted parties can advocate for relief.
For more information about how these trends affect your sanctions compliance program, click here to read the Client Advisory.