Good Practice

Detecting front companies in a changing export control and sanctions landscape

Issue 12
April 2021

Author
Robert Shaw
+ About author

Robert Shaw is Program Director for the Export Control and Nonproliferation Program (XNP) at the James Martin Center for Nonproliferation Studies at the Middlebury Institute of International Studies. rashaw@middlebury.edu

To stay ahead of the sanctions and export control evaders, it’s important to think like the evaders.

Recent additions to the BIS Entity List, the introduction of new military end use and end user controls, expanded US and EU sanctions regimes addressing human rights concerns, and the use of short-supply export controls related to the Covid-19 pandemic have targeted or are impacting a wider range of supply chains. Entities in these supply chains may establish front companies to circumvent the...

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