Good Practice

What does a “risk-based” compliance program mean?

Issue 34.
June 2023

Author
Stephen Wilcox
+ About author

Stephen Wilcox is a Managing Director in the Export Controls and Sanctions offering at FTI Consulting, and is based in Washington, DC He specializes in US and foreign export controls and sanctions matters. steve.wilcox@fticonsulting.com

As of the events occurring in 2022, government regulatory and enforcement agencies have started to promote the concept of companies creating and maintaining a “risk-based” approach to compliance. Though this approach to compliance has only recently been promoted to the private sector, the risks behind the need for the new approach have been prevalent for decades.
So what does it mean to have a risk-based approach to compliance with multilateral export controls and sanctions? The comments as stat...

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