McGuireWoods Lawyers Write Chapter for GIR’s “The Guide to Sanctions”

July 13, 2022

McGuireWoods partners Alex Brackett, Patrick Rowan, Jason Cowley, Laura Colombell Marshall and Edwin Childs and associate Elissa Baur contributed to Global Investigations Review’s publication “The Guide to Sanctions ─ Third Edition.” The lawyers wrote the chapter titled “Impacts of Sanctions and Export Controls on Supply Chains,” published July 8, 2022.

The updated edition — which expands upon the chapter that Brackett, Rowan and Cowley penned last year for the guide — cited as a key example the sanctions stemming from Russia’s invasion of Ukraine earlier this year.

“Sanctions and export controls can be nimble and quickly deployed, as we have seen in the case of the response to Russia’s invasion of Ukraine,” the authors wrote. “Taking largely unforeseeable circumstances such as Russia’s aggression into account, having a well-trained compliance function in place, supported by trusted outside advisers, is the key to having the system resiliency needed to rapidly pivot in the wake of precipitous sanction and export control developments.”

The article provided an overview and background on sanctions and export controls, which can vary by country and transaction, and discussed how controls and sanctions overlap, interact and evolve. It also set out compliance strategies addressing risk analysis, resource allocation, training, due diligence and screening.

The attorneys recommended that companies implement a well designed, risk-based compliance program “tailored to a company’s specific circumstances, including the risk profiles of its suppliers, intermediaries and customers” to help them identify and address challenging sanction developments.

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