Good Practice

Identifying potential violations

Issue 54.
June 2025

Author
Elizabeth ShinglerSteven Brotherton
+ About author

Elizabeth Shingler (Richmond) is a Senior Manager in the Global Export Controls and Sanctions practice of KPMG LLP. eshingler@kpmg.com

Steven Brotherton (San Francisco) is a Principal in the Global Export Controls & Sanctions practice of KPMG LLP and leader of the service line. sbrotherton@kpmg.com

KPMG: SMART PRACTICE
When a potential violation is identified, the export compliance team has to develop a plan to ensure the violations are not continuing and take steps to prevent future violations. In assessing next steps, the team should take certain actions to fully understand the situation, inform stakeholders and remediate the challenge.
1. Gather the facts
When a potential violation first comes to light, the facts around how it occurred may not be entirely clear. It will be important to ...

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