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Supply Chain Due Diligence and OFAC

OFAC enforcement is evolving. Learn more about how sanctions may impact supply chain due diligence with PSA's brief.

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Featured Insights

Understanding “Abnormal Operations” in China

In 2014, regulations outlining information disclosure requirements for Chinese companies created a List of Companies with Abnormal Operations (“the Abnormal Operations List”; 企业经营异常名录). The list includes companies that have failed to comply with information disclosure requirements.

There are four circumstances under which a company would be added to the list:

...

Managing Cross-Border Asset Tracing and Recovery Investigations

Asset recovery in international fraud cases can present considerable challenges and risks. After building a case and pursuing recoveries across diverse jurisdictions, victims may still recover only pennies on the dollar. In this episode, Martin Kenney of Martin Kenney & Co. shares his unparalleled insights into creating layered strategies and managing multidisciplinary...

Supply Chain Due Diligence and OFAC

As companies work to rebuild global supply chains, PSA examines the case of e.l.f. Cosmetics, Inc. and its fine for sanctions violations. The DOJ found that these violations occurred because of a “largely inadequate” compliance program. The individual unit cost of the items were low,  and only limited elements of...

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