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By Adam Turteltaub
The US Foreign Corrupt Practices Act and similar anti-corruption laws around the globe get the lion’s share of attention, but as the Wall Street Journal recently reported, sanctions accounted for 56% of fines in the last ten years, totaling $26 billion worldwide.
Suzanne Bullitt, who is Director, Global Trade Strategy & Compliance at the Eastman Chemical Company, is well aware of the compliance risk. She has to be.
Suzanne took the time to share with us in this podcast a wealth of advice for anyone who oversees export compliance, or is wondering if the people who are supposed to be doing it are truly on the ball. Hear her advice such as:
- Ensure that all of your classifications are accurate and harmonized, and watch out for manipulations from the business units
- Make sure that classifications are consistent, accurate and declared properly
- Take the time to understand the regulatory requirements and country-specific requirements for both export and import
- Be absolutely certain who the end user of your goods are, including who owns over 50% of the company
- Be especially alert with joint ventures
- Don’t forget to examine all parties to the transaction, including bankers, vendors and even the ships the goods sail on
If you have trade compliance risks, take advantage of Suzanne’s wisdom. It may help your organization avoid becoming a part of the next $26 billion in fines.
This is great and timely piece of advice as most companies are looking forward to minimize costs and maximize profits as much as possible , and to improve productivity , enhance efficiency and eliminate operational risks at all costs. As much as it’s agreeable that violators of ethical and compliance laws are penalized, it is equally important for regulators and compliance officials to go further by extending the penalties to the other accomplices down the supply chain or even the end users who may be involved one way or the other in such unethical and non compliant activities in order to ensure absolute sanity and professionalism in the corporate sector or even in governance.
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