STEPTOE: OUTSIDE COUNSEL
Confusion abounds over the recent proliferation of sanctions and export control lists. In addition to the US Treasury Department’s Office of Foreign Assets Control (“OFAC”), companies now have to contend with lists from, among others, the Commerce Department’s Bureau of Industry and Security (“BIS”), the State Department, numerous state-level divestment authorities, and even the Department of Defense (“DoD”).
List management and name screening are greatly simplifi...
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