Steptoe partner Wendy Wysong and Bliss Khaw, principal at Control Risks, co-authored a chapter in the Navigating the Global Sanctions Landscape in 2024 report published by Control Risks. The chapter, "Sanctions Aren't the New FCPA - They're Harsher" discusses sanctions enforcement and the Foreign Corrupt Practices Act (FCPA). Companies facing enforcement for export controls and sanctions violations will face a harsher reality than they ever have for FCPA violations. Agencies have administrative authority to not only shut a company out of the US financial system but also cut off access to critical technology, freeze assets, and administer monetary fines based on strict liability. The intersecting security, economic, andgeopolitical considerations driving the creation and enforcement of these sanctions regimes present a significantly more complex set of issues for businesses to navigate than FCPA and anti-bribery and corruption regulatory compliance.
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