Patrick Rowan and
Jason Cowley contributed to the Global Investigation Review's publication “The Guide to
Sanctions ─ Second Edition.” They wrote the chapter “Impacts of Sanctions and Export Controls on Supply Chains,” published July 13, 2021.
“Today’s globalized, on-demand supply chains rely on increasingly seamless
cross-border movements of raw materials and goods in order to be cost
efficient and effective,” the authors noted. Sanctions and export controls,
however, present potential impediments that can imperil that supply chain
and the company’s performance.
To manage these issues, the authors recommended implementing a
“well-designed, risk-based compliance programme tailored to a company’s
specific circumstances, including the risk profiles of its suppliers,
intermediaries and customers.”
The article provides an overview and background on sanctions and export
controls, which can vary by country and transaction, and discusses how
these controls and sanctions overlap, interact and evolve. The article also
sets out compliance strategies addressing risk analysis, resource
allocation, training, due diligence and screening.