Compliance, Ethics & Sustainability Voorheen tijdschrift voor Compliance 2023 nr. 5

A Framework for Effective EU Sanctions Compliance Programs

Jan Dunin-Wasowicz1

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Companies in the European Union ("EU”) stand at the forefront of implementing EU restrictive measures (broadly speaking, sanctions) and are the first line of defence against those trying to evade or circumvent them. Although entities subject to EU law (EU operators) have borne that responsibility ever since the EU began to adopt sanctions, the measures introduced following Russia’s full-scale invasion of Ukraine and the complexities of today’s tumultuous world have significantly increased that burden. Today, EU operators must navigate a dynamic sanctions environment fraught with heightened legal and reputational risks. However, until recently, they have largely been left on their own to accomplish this challenging task. Nearly twenty years after the publication of the first guidance on EU sanctions implementation, the EU has yet to articulate a common holistic view on sanctions compliance expectations for the private sector.

EU sanctions legislation does n...

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Verder in dit artikel:

1. The Genesis of EU Sanctions Compliance Guidance

2. EU Due Diligence Guidance

3. The Need for Programmatic Compliance Guidelines in the EU

4. Principles for a Common EU Sanctions Framework

5. Conclusion

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Artikel informatie

Jan Dunin-Wasowicz1
Ik ben auteur van dit artikel
Datum artikel
Uniek Den Hollander publicatienummer

Verder in 2023 nr.5


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