Good Practice

Managing trade compliance investigations in a Covid climate

Issue 11.
March 2021

Author
Aiysha HussainTimothy O’Toole
+ About author

Aiysha Hussain is a Counsel at Miller & Chevalier Chartered in Washington, DC. www.millerchevalier.com

Timothy O'Toole is a Member at Miller & Chevalier Chartered in Washington, DC. www.millerchevalier.com

A s Covid-19 has spread around the world, compliance and investig­ative functions have been forced to adjust to the new paradigm of social distancing and quarantine measures. Recognising the shift, early on the US Treasury’s Office of Foreign Assets Control (‘OFAC’) issued a notice acknowledging that companies may need to temporarily reallocate sanctions compliance resources because of Covid-19, and that OFAC would evaluate this as a factor in determining an appropriate response to an apparent v...

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