Dave Stetson has authored an article for Export Compliance Manager titled "Evasion of Sanctions and Export Controls: Red Flags and Responses." The piece discusses a range of activities that companies should pay attention to when analyzing third-party intermediaries or transshipment points for sanctions evasion, including: unexplained changes in behavior; reluctance to share information regarding product end use; personal email account usage; and more. Dave explains, "a robust compliance program that detects and responds to indicators of evasive activity is a company's best defense" against enforcement actions or investigations by the US authorities.
The full article can be read at Export Compliance Manager (subscription required).
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