Compliance With International Sanctions: “Facilitation” and “Circumvention” – Considerations for EU Citizens and US Nationals Wherever They Are Located

July 20, 2012
Restrictions on where your company can do business, prohibitions on those entities and individuals with whom you can engage, and wider measures relating to export and investment activity implemented under EU and US sanctions legislation trigger a wide range of offences. Companies on both sides of the Atlantic as well as European and US nationals employed outside the EU and US need to consider and comply with these measures in order to manage their corporate and individual personal liabilities. This update considers the offences of “facilitation” and “circumvention” and the associated compliance challenges for your company.“