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Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
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Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
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Print Share by Email Share Back to top The Trump Administration’s crackdown on cartels and transnational criminal organizations (TCOs) operating abroad and in the United States is a significant Department of Justice (DOJ)...more
Geopolitical risks to supply chains are top of mind across C-suites, but few say what it means. The term “geopolitical risk” has largely become a code word for import, export, and economic sanctions compliance. ...more
U.S. and Mexican companies and financial institutions are seeking to navigate AML/CFT, sanctions, export control, and tariff and supply chain concerns as their governments’ make rapid changes around trade and tariffs and ramp...more
Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more
Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more
Geopolitical risks to supply chains are top of mind across C-Suites but few say what it means. The term “geopolitical risk” has largely become a codeword for import, export, and economic sanctions compliance. The fast pace of...more
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to...more
On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more
We are entering a year of acute political risk for international trade, with a high likelihood that the Trump administration will hit China with punitive tariffs and increased export controls. Against the backdrop of trade...more
On January 2, 2025, the US Department of Defense added a number of entities to its list of “Chinese military companies" (CMC List). While being named to this list, by itself, does not prohibit US businesses from continuing to...more
While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more
Regulators have sent numerous messages that companies who source from abroad need to subject their entire supply chain to extensive due diligence, based on state-of-the-art compliance measures to minimize supply chain risks....more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
Both enforcement agencies and consumers increasingly are focused on manufacturers’ supply chains. Human rights enforcement frameworks increasingly have real teeth. Both the United States and the European Union either have, or...more
Human rights assessments are an increasingly closely watched area of due diligence for the supply chain of organizations across numerous industries. Even smaller operators are subject to the reality of today’s global supply...more
The Canadian Institute’s 7th Annual Canadian Forum on Global Economic Sanctions returns to Toronto in-person and via livestream on September 22-23! Join a Canadian and international faculty of government of officials,...more
Are you looking to hire a star engineer who is a foreign national? Are you considering raising capital from a foreign venture capital firm or other foreign investor? Are you interested in sourcing components or creating...more
As the global economy faces the third year of the pandemic, manufacturers are no longer focused on figuring out when things will return to “normal.” Instead, they are applying lessons learned from the past few years to become...more
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international...more
The threats posed by Russia to the Ukraine, and the worldwide implications, are deeply concerning and we denounce the invasion of the Ukraine by Russia and hope that this crisis can be resolved quickly through diplomacy. ...more
President Biden signed into law on December 23 legislation that will, for the first time, require U.S. Customs and Border Protection (“CBP”) to detain all imports that are made wholly or partly in the Xinjiang Uyghur...more
As a preface to this blog, I recently gave a presentation with Nate Picarsic and Emily de la Bruyere at the American Bar Association Public Contract Law Section Fall Procurement Symposium on “China’s Military-Civil Fusion...more
Moving on, 2019 was a big year in OFAC compliance. The Sanctions Compliance Guidance was a major change in sanctions compliance. OFAC has set high expectations for compliance. Whether companies have received and responded to...more
Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more