FCPA Compliance Report

Matt Silverman on Preparing for Potential Sanctions Against Russia

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In this episode of the FCPA Compliance Report, I am joined by Matt Silverman, Director of Trade Compliance at VIAVI. In Part 1, we considered the potential U.S. sanctions if Russia invades Ukraine. In this Part 2, we discuss what you can do to prepare for such an eventuality. Highlights in include:

  • First, ascertain your exposure and consider how some or all of these actions would impact your business. 
  • Check your sanctions screening policies and procedures and check your customers and business partners in real time against global sanctions lists. 
  • Identify all of your contracts with Russian entities or individuals and review your contracts for compliance with law clauses, notice clauses, and termination provisions.
  • Know your customer. 
  • Identify what, if any, items, or technology you are exporting to Russia and any transactions with Russian entities that have ongoing or continuing obligations. 
  • Take a look at your supply chain to avoid business interruption. 
  • Identify whether you have any outstanding debts from Russian entities or individuals, and, if so, promptly purse collection activities. 
  • Identify any procurement or manufacturing activities for goods intended for Russia and consider whether you can safely postpone or delay those activities, especially if you are dealing with specially designed or non-fungible goods (without breaching any contracts or risking failure to meet deadlines).

    • Resources

    Matt Silverman on LinkedIn

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    FCPA Compliance ReportBy Thomas Fox
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