Fcpa Compliance Report

In this episode of the FCPA Compliance Report, I am joined by Matt Silverman, Director of Trade Compliance at VIAVI. In Part 1, we considered the potential U.S. sanctions if Russia invades Ukraine. In this Part 2, we discuss what you can do to prepare for such an eventuality. Highlights in include: First, ascertain your exposure and consider how some or all of these actions would impact your business.  Check your sanctions screening policies and procedures and check your customers and business partners in real time against global sanctions lists.  Identify all of your contracts with Russian entities or individuals and review your contracts for compliance with law clauses, notice clauses, and termination provisions. Know your customer.  Identify what, if any, items, or technology you are exporting to Russia and any transactions with Russian entities that have ongoing or continuing obligations.  Take a look at your supply chain to avoid business interruption.  Identify whether you have any outstanding de