Firms with international supply chains confront a complex web of sanctions and export controls imposed by the US and the European Union (EU), among others. To avoid getting caught in this web, it is essential that companies develop and implement a compliance programme tailored to the special risks associated with their supply chain and operations. To that end, firms must identify the activities within their organisation that pose potential compliance risks, determine if they have ‘controlled’ items in their supply chain, determine if they have transactions involving embargoed countries or sanctioned entities and adopt policies and procedures that prevent exports and transactions that run afoul of US and EU regulations.

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