The importance of supply chain due diligence and the risks of modern slavery – OFAC settles North Korean sanctions case with fine

Authors: Kyle Wombolt, Jeremy Birch, Antony Crockett and Emily Purvis.

A recent enforcement action by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) against US company e.l.f Cosmetics Inc (ELF) highlights the importance of supply chain due diligence in conducting cross border business. The action against ELF reflects a global trend of increased regulatory focus on supply chains in relation to a range of business conduct issues, including corruption, modern slavery, and other human rights violations. To mitigate sanction violation risk, companies should verify the country of origin of goods and services in their supply chains.

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US PRESIDENT SIGNS IRAN, NORTH KOREA AND RUSSIA SANCTIONS BILL – WITH TWO SIGNING STATEMENTS

H.R. 3364 (the “Countering America’s Adversaries Through Sanctions Act”) overwhelmingly passed the House and Senate and has now been signed into law by the US President, albeit with two partly critical signing statements (here and here). The law represents significant development in sanctions against Iran, North Korea, and Russia.

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