How context matters for effective compliance
In the beginning...
I started my legal career 30 years ago as a compliance officer in the US Commerce Department’s Office of Antiboycott Compliance, which was (unfairly in my opinion) considered something of a backwater, in what was then known as the Bureau of Export Administration. So OAC was part of BXA, which ultimately became BIS, where it still resides (I know I don’t even need to explain these acronyms to my august readers). Anyway, backwater or...
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