Good Practice

Pausing exports: When, Why and how

Issue 18.
November 2021

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 export control or sanctions violation is identified, the export compliance team digs into the matter to identify the root cause, determine next steps and implement corrective actions. However, sometimes the team realizes that egregious violations are on-going and remediating these issues will require a coordinated, enterprise-wide approach. For example, in one prominent case an employee altered invoices and shipping documents, listed false license numbers on ...

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