Trade Sanctions: Navigating Compliance in a Rapidly Changing Landscape

© 2015 Baker & McKenzie LLP
GOOD. SMART. BUSINESS. PROFIT.
TM

Trade Sanctions:
Navigating Compliance in a Rapidly
Changing Landscape
April 8, 2015

Chelsie Chmela
Events Manager
Chelsie.chmela@ethisphere.com
847.293.8806
We encourage you to engage during the Q&A portion of
today’s webcast by using the chat function located within
your viewing experience.
HOST
QUESTIONS
RECORDING
The event recording and PowerPoint presentation will be
provided post event.
3

4
SPEAKING TODAY
Karl Laskas
Executive Director, Global Trade and Compliance, Dell
Tom Firestone
Partner, Baker & McKenzie, Washington, DC
Steven Hill
Counsel, Baker & McKenzie, Washington, DC
Tristan Grimmer
Senior Associate, Baker & McKenzie, London

Baker & McKenzie LLP is a member firm of Baker & McKenzie International, a Swiss
Verein with member law firms around the world. In accordance with the common
terminology used in professional service organisations, reference to a "partner"
means a person who is a partner, or equivalent, in such a law firm. Similarly,
reference to an "office" means an office of any such law firm.
8 April 2015
Trade Sanctions: Navigating Compliance
in a Rapidly Changing Landscape
Karl Laskas, Executive Director, Global Trade and Compliance, Dell
Tom Firestone, Partner, Washington, D.C.
Tristan Grimmer, Senior Associate, London
Steven F. Hill, Of Counsel, Washington, D.C

Agenda
• Introduction
• US and EU trade controls: A high-level perspective
• Hypothetical
• Current status:
• Cuba
• Iran
• Conclusion
6

7
Congratulations!!!
You have just been hired as the new International Trade
Compliance Manager for CommuniCo, a US-
headquartered multinational manufacturer and supplier
of electronics and telecommunications-related
equipment for companies in the manufacturing, energy
and extractive industries. CommuniCo has a number of
wholly owned subsidiaries around the world.
On your very first day, you receive an email from the
company’s US-based project development team. There
is a hot opportunity to sell equipment and services to a
Russian company. They need a compliance review by
COB today. Can we do it?

Export Controls and
Sanctions – A High-Level
Overview

• Export Administration Regulations (“EAR”) – Enforced by US Bureau of
Industry and Security (“BIS”)
• Controls dual-use items (having military and civilian applications)
• “EAR Items” includes US origin items and foreign produced items with
greater than de minimis US controlled content
• Authorization may be required depending upon the product classification,
end destination, end user and end use
• International Traffic in Arms Regulations (“ITAR”) – Enforced by Directorate of
Defense Trade Controls (“DDTC”)
• US or non-US Persons dealing in US defense articles/services
• License generally required to any destination
• Important feature of US export control laws – Control follows the item outside
US territory
• EAR controls apply to EAR Items located anywhere globally, even in
transactions with no nexus to US territory
9
Export Controls – United States

• Dual-use: EU Regime
• Controls export of dual-use items
• Applies mostly to exports to outside the EU (controls for intra-
EU transfers only in limited cases)
• Applies directly in all 28 EU Member States
• Military: Member State Regimes
• Control export of military items
• Applies to exports to outside of Member State
• End-use: EU Regime
• Controls supply of non-controlled items for WMD and Military End-
use
• Licensing and enforcement dealt with at Member State level
10
Export Controls – European Union

Sanctions General Applicability – United States
• Apply to “US Persons”
• Entities organized under US laws and their non-US branches
• Employees (regardless of nationality) of above entities
• Individuals and entities in the United States
• US citizens and permanent resident aliens (“Green Card” holders)
wherever located or employed
• Non-US Persons may be subject to US jurisdiction if they cause prohibited
transactions to occur in whole or in part in the United States or anywhere by
US Persons
• Example – Use of US Dollars for sanctioned country transactions
• Separately incorporated foreign subsidiaries of US companies
are NOT US Persons
• Exception – Cuba and Iran sanctions apply to any entity (including foreign
entities) owned or controlled by a US Person
11

Sanctions General Applicability – United States (2)
• Comprehensive sanctions target Cuba, Iran, North Korea, Sudan and Syria
• Prohibition extends to dealings with the governments of these counties and
certain persons and entities designated under these sanctions programs
(Specially Designated Nationals (“SDNs”))
• Significant sanctions:
• Burma/Myanmar (largely suspended through OFAC general licenses)
• Russia (more on this later)
• Persons and entities (SDNs) associated with certain repressive regimes (e.g.,
Belarus, Venezuela, Zimbabwe)
• Persons and entities (SDNs) associated with activities not tied to specific
countries or regimes (e.g., terrorists, WMD proliferators, narcotics traffickers)
• US Persons comprehensively prohibited from engaging directly or indirectly in
transactions with sanctions targets without government authorization
• Prohibition extends to “facilitation” (generally, support of another person’s
transaction with a sanctions target that the US Person could not engage in
directly), as well as “evasion”
12

Sanctions General Applicability – United States (3)
• US sanctions on SDNs:
• Prohibition on US Person dealings with SDNs, or the property and interests
in property of SDNs, whether directly or indirectly
• SDN prohibition extends to any entity owned directly or indirectly 50% or
more by one or more SDNs even if such entity is not itself designated as an
SDN
• Same principle applies for Russian entities designated under “sectoral”
sanctions – their 50%+ owned entities must be treated as subject to the
same sectoral sanctions restriction
• Requirement to block/freeze SDN property and interests in property and to
report such blocking to OFAC
13

Sanctions General Applicability – European Union
• EU sanctions measures typically apply to:
• Any entity incorporated in an EU Member State and its EU and non-EU
branches
• Any entity incorporated outside the EU, but only in respect of any business
conducted in the EU
• Any directors, officers, employees, agents, etc. located in the EU
(irrespective of nationality)
• Any directors, officers, employees, agents, etc. that are nationals of an EU
Member State (even if located outside the EU)
14

Sanctions General Applicability – European Union (2)
• EU restrictions on transactions with Designated Persons (“DPs”)
• Prohibition on “making available” “funds” or “economic resources”, directly
or indirectly, to or for the benefit of DPs
• Freeze on funds and economic resources belonging to, owned, held or
controlled by DPs
• Administered and enforced by each EU Member State
• Other EU sanctions measures include
• Arms embargoes
• Prohibition on the supply of certain goods and technology
• Prohibition on the provision of related services, including financing and
brokering activities
• Prohibition on the purchase of certain goods
• Prohibition on investment in certain sectors
15

Russia – US Sanctions (Executive Order 13662)
17
• Jurisdiction: applies to US Persons, which does not include
separately incorporated non-US subsidiaries
• SDNs: approximately 117 individuals and entities explicitly
listed
• Sectoral Sanctions: target entities in Russia’s financial services,
energy, and defense sectors; specific restrictions apply
depending on the applicable directive
• Directive 1 (financial services): “new debt” of longer than 30 days maturity or
“new equity”
• Directive 2 (energy): “new debt” of longer than 90 days maturity
• Directive 3 (defense): “new debt” of longer than 30 days maturity
• Directive 4 (energy): targeted energy projects (deepwater, Arctic offshore,
shale) that have the potential to produce oil in Russia (excludes financial
services)

US sectoral sanctions targeting Russia
18
Sectoral Sanctions Identifications List Directives
Entity Name Date Sanctioned Directive No.
AK Transneft 9/12/14 2
Bank of Moscow 7/29/14 1
Gazprom 9/12/14 4
Gazprom Neft 9/12/14 2 & 4
Gazprombank 7/16/14 1
Lukoil 9/12/14 4
Novatek 7/16/14 2
Rosneft 7/16/14 2 & 4
Rostec 9/12/14 3
Russian Agricultural Bank 7/29/14 1
Sberbank of Russia 9/12/14 1
Surgutneftegas 9/12/14 4
Vnesheconombank 7/16/14 1
VTB Bank 7/29/14 1
An entity 50% or more owned by one or more of the above sanctioned parties is subject to the same directives.

Russia – US Export Controls
19
• Jurisdiction: items subject to the EAR
• Russian Oil Industry Sanctions program
• License requirement for items subject to the EAR described in
Supplement No. 2 to EAR Part 746 or selected ECCNs for
deepwater, Arctic offshore, or shale formation projects in Russia that
have potential to produce oil or gas
• Policy of denial for projects with potential to produce oil
• Additional Export Controls
• Entity List designations (specific energy and defense companies)
• EAR licensing requirement for certain items intended for military end
use or end-users in Russia
• Policy of denial for export/reexport of “high technology” items that
may contribute to Russian military capabilities (ITAR & EAR)

Russia – US Trade Embargo on Crimea
20
• Executive Order 13685 (Dec. 19, 2014):
• Crimea region of Ukraine
• US Persons prohibited from new investment, export/supply of
services
• Import ban
• General License No. 4: agricultural commodities, medicine,
medical supplies, and associated replacement parts
• General License No. 5: wind-down activities; expired Feb. 1
• Export Ban (Jan. 29, 2015):
• License requirement for all items subject to EAR, with policy
of denial
• Exclusions for EAR99 food or medicine

Russia – European Union Restrictions
21
• Designated Party Controls: 173 individuals and 37 entities (including
one bank)
• Financial Controls:
• Dealings in certain financial instruments issued by, and provision of
new debt/credit to listed financial, oil and military parties
• Energy Sector:
• Certain oil and gas equipment and technology
• Provision of drilling, well testing, logging and completion services,
and supply of specialised floating vessels
• Focused on deep water, arctic and shale projects
• Export Controls:
• Any dual-use items to military end-user/end-use or to 9 listed
entities
• Arms embargo

• Import prohibition
• Prohibition on import into the EU of “goods originating” in Crimea/Sevastopol
• Provision of related financing or financial assistance or (re)insurance
• Export/supply prohibition
• Prohibition on export to or supply to Crimea/Sevastopol of items used in targeted
sectors and beyond (!)
• Transport
• Telecommunications
• Energy
• Oil & gas and minerals
• Prohibition on provision of related services
• Investment prohibition
• Extends to all sectors
• Includes investment in real estate
• Tourism activities
• Ban on “directly” related services
22
Crimea and Sevastopol – EU Restrictions

24
Congratulations!!!

25
Congratulations!!!

26
Congratulations!!!
US Rules
• You – US Person wherever located or employed globally
• CommuniCo – US Person including branch offices
• Separately organized foreign subsidiaries not subject to US
sanctions (except Cuba and Iran)
• US parent must avoid facilitation concerns with respect to foreign
subsidiaries’ transactions with sanctions targets
• Facilitation may include approvals, technical assistance,
logistical assistance, sales support, back-office support
• Watch out for EU and other sanctions jurisdiction

27
Congratulations!!!
On your very first day, you haven’t even located the
coffee maker when you sit down at your desk, open your
email, and find this urgent inquiry waiting for you from
the company’s US-based project development team:
EU Rules
• EU incorporated companies are subject to EU sanctions wherever they
do business (includes overseas branch offices)
• Employees that are nationals of EU Member States are subject to EU
sanctions wherever they are located
• Non-EU companies and non-EU nationals are caught in relation to acts
within EU territory

28
Congratulations!!!
• Indicates US Persons (company and individuals) heavily involved in the
transaction
• If a US sanctions roadblock arises, the company may not be able to
transfer further development of the deal to non-US Persons (facilitation
issues)
• Don't forget about EU nationals: treat them in a manner comparable to
US nationals located overseas

29
CommuniCo has the chance to bid on a USD 10 MM sale of
equipment to RussCorp, a Russian company specializing in
oil and gas prospecting and extraction. RussCorp is 60%
owned by Rosneft, a major Russian oil and gas company,
with 40% owned by an obscure foundation established in
Liechtenstein. CommuniCo’s equipment will be for use in
RussCorp’s new O&G operations in the Sea of Azov, a
shallow (< 50 foot depth) arm of the Black Sea situated
between Russia, Ukraine, and Crimea. RussCorp supports
both its Sea of Azov as well
as deep-water Black Sea
operations from Russian
supply bases, but is looking
at establishing additional
supply bases in Crimea.

30

31
Russia – Not comprehensive sanctions, but requires heightened diligence
Oil and gas – Be on the lookout for business sectors of higher risk (energy
and extractive, defense, banking, health care)
Think about other potential risk areas, such as anti-corruption and money
laundering

32

33
Rosneft
• Designated on OFAC’s SSI List (“sectoral” sanctions)
• Subject to OFAC Directive 2 (new debt restrictions) and Directive 4
(deepwater, Arctic offshore and shale oil development and production
restrictions)
• Targeted under EU capital markets and loan/financing measures
OFAC designations (SDNs and SSI)
• Include any entity owned 50% or more by one or more designees
• RussCorp therefore must be treated as subject to the same SSI
designations as Rosneft
EU capital markets/financing measures:
• Entities (such as RussCorp) owned more than 50% by targeted entities
also caught (contrast with DP test)
• Also apply to entities "acting on behalf of or at the direction of" targeted
entities

34

35
What is this foundation? Who owns or controls it?
• Many Russian investors hide their ownership interests behind off-shore
entities or front men
• May need to conduct further diligence to discover persons behind
foundation
• If person is an SDN or DP, this could create problems if they benefit from
CommuniCo’s transactions with RussCorp or if funds are transferred
directly or indirectly to them
• Potential money laundering concerns if their investment represents the
proceeds of crime
• Note: EU DP test not only concerned with majority ownership; also
applies to entities controlled by DPs

36

37
Sea of Azov
• Part of maritime area claimed by Russia
• Not deepwater (i.e., over 500 foot or 150 meter depth)
• Should not trigger US Russia sanctions targeting oil and gas drilling
and production activities in deepwater depths
• EU sanctions apply irrespective of oil and gas application;
distinction is the ability to get a license to supply

38

39
• RussCorp is subject to OFAC Directive 4, which prohibits the export or
reexport of goods, technology or services for, inter alia, deepwater
production in maritime areas claimed by Russia
• What controls are in place to ensure that CommuniCo products are not
diverted to RussCorp’s deepwater operations in the Black Sea?
• CommuniCo could be held liable for turning a blind eye to these risks

40
• EU sanctions controls on supply of certain oil sector equipment apply
irrespective of customer/end-user
• EU License required for supply of targeted equipment irrespective of
whether being used in unconventional segment
• License may not be granted where EU Member State has "reasonable
grounds to determine" that items are destined for a deepwater (or Arctic or
shale) project
• Breach to supply without duly granted license

41

42
• The Crimea region of Ukraine is now subject to comprehensive US
sanctions, broadly prohibiting the export of most goods directly or
indirectly there
• What controls are in place to ensure that RussCorp does not transfer or
stage CommuniCo’s equipment there?
• CommuniCo could be held liable for turning a blind eye to these risks
• Any US goods shipped there in violation of the EAR would be “tainted,”
which would prohibit CommuniCo’s future servicing of them without a BIS
license

43
• EU imposed comprehensive embargo on import of products from Crimea
and investment into Crimea
• Additionally, extensive list of products prohibited from being supplied to
Crimea; prohibition relates to supplies to, or for use in, Crimea
• Supplies to Russia not caught where there are "no reasonable grounds to
determine" that the items are for use in Crimea

44
CommuniCo prides itself on its ability to supply customers
from a seamless global production platform, and will
structure its bid assuming the supply of a mix of equipment
from facilities in both the United States and European
Union. It is expected that supply of the equipment will occur
in tranches over the next 24 months, with RussCorp placing
orders on an as-needed basis.
As part of its standard sales package, CommuniCo
technicians from both the US and EU will be supplied to
commission the equipment once it is installed by RussCorp.
There is also a standard 60 month warranty for repair and
replacement of any defective equipment.

45

46
Think about the jurisdictional issues that will apply:
• Equipment shipped from the US subject to the EAR and OFAC rules
• Equipment shipped from the EU subject to EU sanctions and export
controls
• Product controls under EU sanctions are not limited to items exported
from EU territory, but also apply to the supply and transfer of items from
outside of EU where undertaken by EU incorporated company (includes
transfers inside sanctioned country)
• US-origin equipment shipped from the EU, and EU equipment produced
with over 25% controlled US content also subject to the EAR
• Any US support of EU shipments (technology assistance, logistics, sales
support, approvals) raises facilitation issued under OFAC rules
• EU sanctions do not contain as extensive a facilitation prohibition (but
note controls on "brokering“)

47

48
Each new shipment will require heightened diligence:
• Has the scope of sanctions changed?
• Destination of individual shipments (note the risks related to Crimea and
deepwater production)
• Will require careful management of shipments to determine what is subject
to US versus EU jurisdiction
• Consider contractual protections upfront

49

50
• Supply of technical service from the US and EU will trigger US and EU
sanctions, respectively
• Any equipment that was shipped in violation of the EAR (e.g., stored in or
supplied from Crimea) is “tainted” and cannot be serviced by any person
without BIS authorization
• Ongoing servicing will require diligence every time there is a servicing or
warranty claim

51
Finally, for tax and liability reasons CommuniCo has
decided that the company’s wholly owned subsidiary in
France will be the entity to contract with RussCorp.
Payment will be by Letter of Credit, with payments
denominated in US Dollars to an account in France.

52
denominated in US Dollars to an account in France.

53
denominated in US Dollars to an account in France.• Letter of Credit is considered a “debt” instrument subject to OFAC
Directives under the Russia sanctions
• Likely also caught by EU measures relating to new loans or credit; contrast
with payment terms
• US Dollar payments can trigger US sanctions liability, even with no other
US jurisdictional nexus, under the theory that such payments are cleared
through US banks, causing those banks (which are US Persons) to support
sanctioned transactions in violation of US laws
• Non-US banks initiating US Dollar payments for sanctioned country
transactions have incurred hundreds of millions of dollars in OFAC liability
under this causation enforcement theory

Current Status – Cuba
and Iran

© 2015 Baker & McKenzie LLP 55
Cuba Sanctions – What Has Changed?
• Travel (12 specific categories)
• Authorized by general license vs. specific license
• Non-charter flights between United States and Cuba
• Payments by US credit/debit cards
• Private sector support
• Exports/reexports to private sector or telecommunications sector in Cuba
• Imports of Cuban private entrepreneur goods/services into US
• Consumer communications services/items; telecommunications
• Banking
• Authorized travelers in Cuba may use US credit/debit cards
• US banks may establish correspondent accounts at Cuban banks
• US banks may acquire Cuban merchants
• Dealings with Cuban nationals in third countries

• The embargo remains in place
• No investments – e.g., JVs, local companies, banking,
infrastructure, utilities, hotels, farms, restaurants, manufacturers
• No establishing or operating an entity or affiliate in Cuba
• No entering into franchise or licensing agreements with Cuban
parties
• Import ban on various Cuban goods into United States (limited
exceptions) or of Cuban goods/services to other countries
• Foreign owned/controlled subsidiaries still covered
• No tourist travel
56
Cuba Sanctions – What Has NOT Changed?

© 2015 Baker & McKenzie LLP 57
Iran – Potential Thaw in Sanctions Front?
• Joint Plan of Action process resulted in agreement on key parameters on April
2, 2015
• Joint Comprehensive Plan of Action to be agreed by June 30, 2015
• No immediate impact on UN, US or EU sanctions
• Roll-back of sanctions depends on Iran fulfilling its obligations
• UN Resolutions will be revoked and replaced with a Resolution addressing
“sensitive technologies” (defined procurement channel)
• US and EU nuclear sanctions will be terminated/suspended, with snap-back if
Iran fails to fulfil its obligations
• Other EU sanctions may also be terminated in whole or in part
• Other US sanctions on Iran under other sanctions measures (terrorism,
human rights abuses, ballistic missile proliferation) will remain in place
• Timetable remains unclear

Thank You
58

Thomas Firestone
Speaker – Washington
T +1 202 835 6126
thomas.firestone@bakermckenzie.com
Speakers
59
Karl Laskas
Speaker – Dell
Karl Laskas serves as Executive Director, Global Trade Compliance
for Dell, a $60B private company which is one of the world’s largest
manufacturers of computers. In that role, he advises it on trade
compliance matters, develops its system of internal controls, designs
the strategy for crossing borders, and leads its worldwide organization
of trade personnel.
Karl is an attorney, licensed in the Ohio and DC bars, with extensive
experience in regulatory law. He holds a JD from the University of
Virginia, an MA in International Relations from Yale, and a BA in
political science and philosophy from the University of Pittsburgh. Karl
also is a licensed US Customs broker.
Prior to joining Dell, Karl led the Trade function for a diversified
manufacturing group, Honeywell Automation & Control Solutions. In
that role, he oversaw trade operations in 135 countries; supported
more than 80 acquisitions; and contributed to the division’s notable
growth and margin expansion during a period in which the business
tripled in size. Prior to his time in Honeywell, Karl was an export
compliance manager for Smiths Aerospace (now part of GE Aviation)
and practiced international trade law with the firm of Thompson Hine.
Karl is married to novelist Gretchen Moran Laskas, and has two
children, Brennan and Katja.
Thomas Firestone is a Partner resident in the Washignton
office of Baker & McKenzie, and also is a member of the the
Risk and Compliance Group in the Firm’s London office. His
practice focuses on corruption risks and compliance, including
transactional due diligence and internal investigations. He
frequently moderates and speaks at legal and business
conferences and intergovernmental meetings on crime,
corruption and compliance. He also designed and taught special
courses at a local law school on white-collar crime and on the
US Foreign Corrupt Practices Act (FCPA).
Prior to joining the Firm in 2012, Mr. Firestone worked at the US
Department of Justice, first as an Assistant US Attorney in the
Eastern District of New York and then as Resident Legal
Adviser at the US Embassy in Moscow.

Tristan J. Grimmer
Speaker – London
T + 44 20 7919 1476
F + 44 20 7919 1999
tristan.grimmer@bakermckenzie.com
Tristan Grimmer is a Senior Associate in the EU, Competition
and Trade Department of Baker & McKenzie's London office.
He specialises in advising clients on export controls, sanctions,
and anti-bribery and corruption, with a particular focus on
providing clients from a wide range of sectors (including energy,
technology, manufacturing and financial services) with advice on
compliance programmes and dealing with government
authorities. He has advised clients on the drafting and
submission of voluntary disclosures to government authorities,
and more generally upon the handling of investigations.
Speakers
60
Steven F. Hill is Counsel in the International Trade Compliance
practice in Baker & McKenzie’s Washington DC office. He has
over 17 years of experience in a broad array of international
trade regulation compliance and enforcement matters,
particularly US export controls and sanctions laws and anti-
corruption laws including the Foreign Corrupt Practices Act
(FCPA). Mr. Hill regularly advises multinational businesses on
strategies for responding to government enforcement actions
and submission to government authorities of voluntary
disclosures of presumed violations of international trade laws.
He also regularly assists businesses in conducting international
trade due diligence on proposed mergers and acquisitions,
formation of joint ventures and retention of business partners
and intermediaries. Mr. Hill likewise advises clients on national
security reviews of foreign investments under the procedures
administered by the Committee on Foreign Investment in the
United States (CFIUS).
Steven F. Hill
Speaker – Washington
T + 1 202 835 6121
F + 1 202 416 7115
steven.hill@bakermckenzie.com

Baker & McKenzie LLP is a member firm of Baker & McKenzie International, a Swiss
Verein with member law firms around the world. In accordance with the common
terminology used in professional service organisations, reference to a "partner"
means a person who is a partner, or equivalent, in such a law firm. Similarly,
reference to an "office" means an office of any such law firm.
8 April 2015
Trade Sanctions: Navigating Compliance
in a Rapidly Changing Landscape
Karl Laskas, Executive Director, Global Trade and Compliance, Dell
Tom Firestone, Of Counsel, Washington, D.C.
Tristan Grimmer, Senior Associate, London
Steven F. Hill, Of Counsel, Washington, D.C

This webcast and all future Ethisphere webcasts are
available complimentary and on demand for BELA
members. BELA members are also offered
complimentary registration to Ethisphere’s Global
Ethics Summit and other Summits around the world.
For more information on BELA contact:
Laara van Loben Sels
Senior Director, Engagement Services
laara.vanlobensels@ethisphere.com
480.397.2663
Business Ethics Leadership
Alliance (BELA)

Thursday, April 9 at 12:00 p.m. ET
Fraud & Enforcement Trends in 2015:
Perspectives on Recent DOJ Activities
All upcoming Ethisphere events can be found at:
http://ethisphere.com/events/
PLEASE JOIN US FOR

THANK YOU

Trade Sanctions: Navigating Compliance in a Rapidly Changing Landscape

Recommended

Recommended

More Related Content

What's hot

What's hot (19)

Viewers also liked

Viewers also liked (10)

Similar to Trade Sanctions: Navigating Compliance in a Rapidly Changing Landscape

Similar to Trade Sanctions: Navigating Compliance in a Rapidly Changing Landscape (20)

More from Ethisphere

More from Ethisphere (20)

Recently uploaded

Recently uploaded (20)

Trade Sanctions: Navigating Compliance in a Rapidly Changing Landscape