A primer on “red flags” due diligence first principles
As U.S. business resumed following the Labor Day weekend, a freight forwarder’s settlement with the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) provided a back-to-school reminder of first principles of third-party due diligence.
Background
In the September 3 settlement, Fracht FWO Inc. agreed to pay more than $1.6 million for apparent violations of Venezuela- and Iran-related sanctions programs, which arose fr...
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