Category: Compliance and Due Diligence

Know Your End-User: Supply Chain Diversion Poses Rising Legal Risk

A new lawsuit filed by Ukrainian civilians in U.S. courts illustrates a growing and often misunderstood risk for U.S. technology companies: you can face severe legal and reputational consequences even when you believe you’ve done everything right. In this case, plaintiffs allege that U.S.-made microchips were diverted, without the manufacturers’ knowledge, to the Russian military …

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Case Study: How FiveBy Helped Uncover Sanctions Evasion in Crimea

Client Challenge Following the 2014 U.S. embargo on Crimea, multinational companies faced the risk of violating sanctions due to resellers using sophisticated methods to hide their activities. Automated compliance systems often failed to detect these tactics, resulting in potential fines and reputational damage. The FiveBy Solution FiveBy, a risk intelligence firm, has utilized its human-driven …

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Understanding the EU’s New Criterion on Unsafe Oil Tanker Operations

Companies operating in the maritime, shipping, and oil trade sectors must conduct thorough due diligence to ensure compliance with the EU’s 16th package of economic sanctions related to Russia’s invasion of Ukraine, especially in light of the newly introduced criterion potentially targeting entities that facilitate the activities of unsafe oil tankers. With the EU’s expanded …

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FTC’s Click-to-Cancel Rule: What Subscription Services Need to Know

Introduction The Federal Trade Commission’s (FTC) new “Click-to-Cancel” rule officially went into effect on January 14, 2025 and gives businesses until May 14, 2025 to ensure full compliance. Finalized on October 16, 2024, the rule aims to simplify the cancellation process for consumers who want to terminate recurring subscriptions like streaming services, pet insurance, gym …

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Syria’s Reconstruction: Navigating Sanctions post-Assad

Summary Companies engaged in Syria’s post-Assad reconstruction efforts have significant opportunities in key sectors such as infrastructure, energy, and telecommunications. For businesses investing in Syria’s recovery, understanding and navigating the complicated maze of sanctions compliance is essential to avoiding financial and reputational risks.   Understanding Syria’s Emerging Market As Syria’s political landscape shifts, potential investors …

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Aircraft Leasing Sanctions: Strategies for Lessors and Insurers

Executive Summary The aviation industry is facing heightened risks in the wake of escalating international sanctions and export controls. A stark example of this is Russia’s recent seizure of aircraft owned by Western companies. To mitigate the risk of losing aircraft and other assets, civil aviation lessors and insurers must identify jurisdictions where asset recovery …

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Breaking Financial Ties: EU Sanctions Target SPFS Users Linked to Russia

As part of its 14th package of sanctions, following deliberations with the G7, the European Council sanctioned the System for Transfer of Financial Messages (SPFS). The sanctions prohibit EU entities from connecting to this system or any similar financial messaging service developed by Russia’s Central Bank, barring European Union (EU) operators from conducting transactions with …

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