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721.8 kB - Poledna | Boss | Kurer

721.8 kB - Poledna | Boss | Kurer

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Companies should take appropriate steps to minimizethe risk of infringing trade sanctions by introducingthe following safeguards:Require due diligence in connection with alltransactions. This should involve at least thescreening of all counterparties against theeverchanging sanctions lists that identify thecountries, regimes, entities and persons blacklisted.Trade sanctions can apply to goods,technology licensing and the provision of technicalassistance, and to ancillary services such asfinancing, insurance and transport.Establish internal procedures to ensure promptlegal review in the event a transaction with asanctioned party is identified.Check that the due diligence checklist for mergeror acquisition transactions includes an assessmentfor compliance with trade sanctions.The Authors:David Levine is a partner based in the Firm's Washington,DC, office, and a member of the InternationalTrade Group. He practices before internationaltrade organizations, federal agencies andcourts regarding international trade and relatedregulatory matters. David can be contacted on +1202 756 8153 or at dlevine@mwe.com .Andrea Hamilton is a partner based in the Firm'sBrussels office and a member of the Antitrust &Competition Practice Group. She has representedclients before the European Commission and theEuropean Parliament, as well as the US FederalTrade Commission, the US Department of Justiceand other US authorities. Andrea can be contactedon +32 2 282 35 15 or at ahamilton@mwe.com .10

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