Join Rachel Fiorill, Of Counsel in Morrison Foerster’s National Security practice and former Enforcement Section Chief of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), at the Association of Certified Anti-Money Laundering Specialists (ACAMS) Conference in Las Vegas on October 11, 2022. Rachel will be participating in a session titled “Uncharted Waters: Navigating the Unique Sanctions Risks of Complex Global Supply Chains,” alongside Alex Zerden, Founder and Principal, Capitol Peak Strategies LLC.
The session will focus on:
- Detailing sanctions risks tied to the global complexity of supply chains such as changes in suppliers or trade routes to mitigate issues such as transactions with prohibited persons, entities or jurisdictions
- Analyzing the inter-relationship between sanctions, ESG and responsible business conduct, including how this is shaping the management of indirect risks such as violations of OFAC’s 50% rule to develop beneficial owner controls and the mapping of higher risk exposure
- Outlining the major sanctions trends impacting supply chains, including implementation of the Uyghur Forced Labor Prevention Act, the provision of ‘clear and convincing’ evidence on the absence of forced labor, and the balance of obligations between importers, banks and financers