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 each unit sold were ultimately sourced from DPRK. However this was enough for regulatory action. A timely and cautionary reminder as we all continue to adapt to disruptive and world changing events at speed.
PSA has prepared a brief exploring the implications of this case and describing the importance of a robust supply chain due diligence program that covers not only a company’s suppliers, but also those suppliers’ own affiliates and business partners.Download Whitepaper
PSA offers a broad range of due diligence services that are tailored to our clients’ needs and informed by regulatory requirements and relevant guidance.
PSA has conducted corporate investigations into issues of embezzlement, fraud, corruption and other misconduct in over 50 countries.
Request for a Due Diligence Report
Ready to start a conversation?Get in touch