Good Practice

Detecting front companies in a changing export control and sanctions landscape

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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