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Alexandre Lamy published an article, “Supply Chain Risks Related to US Sanctions and Export Control Issues,” in the February 2019 issue of Baker McKenzie’s “Aerospace & Defense Compliance Bulletin.”  The text of that article is provided below.

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Supply Chain Risks Related to US Sanctions and Export Control Issues

When companies and compliance departments think about US sanctions and export control risks, they often focus on sales to customers and exports/reexports from one country to another.  In that context, the compliance focus is typically on confirming that a customer and other parties involved in a sale and shipment are not restricted parties and that the transfer of a product is authorized under applicable export-control regulations.  This is only half the story.  Companies can have similar risks in their supply chain, which can be disruptive to a company’s operations beyond one transaction or customer relationship if not property managed.