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V11 DW 9.12.18



Sanctions are everchanging. The opportunity to make a costly mistake is growing. Can your team keep pace? Find out how to stay ahead by attending our fast paced and practical conference.

• Learn how to mitigate risks from renowned industry experts • Hear the latest OFAC positions on Iran and Russia • Review the best (and cost effective) ways of complying with the latest export controls and sanctions, requirements for Canada, the EU, and the UK Keynote Speaker:

Kelvin Ong

Chief of the Security Council’s Sanctions Branch, United Nations

To register, call any of the following: (704) 341-2439 | (305) 433-7187 or visit us at

ARE YOU DOING EVERYTHING TO PROTECT YOURSELF AND YOUR ORGANIZATION FROM SANCTIONS RISK? 2 DAYS IN NYC. 30+ EXPERTS. 10 CRUCIAL DISCUSSION TOPICS. No account, business, or financial transaction, no foreign representative or asset is beyond the reach of the ever-changing sanctions requirements. Not complying with sanctions duties is not an option. Our annual cross-sector conference shows you how to mitigate risks by bringing together the top experts in one location over two days to guide you on how to improve your organization’s sanctions compliance. Join 100+ corporate compliance, legal, audit, AML & sanctions executives at global public companies who will be participating in fast-paced, high energy, and fluff-free presentations as key strategists and industry experts answer all your tough questions.




Brenda Perrotti, Vice President and Senior AML Sanctions Manager PNC BANK

Tyler Hand, Global Head of Sanctions, Interdiction & Anti-Corruption WESTERN UNION

Hera Smith, Global Sanctions Compliance Officer AFEX

Joe Soniat, BSA/AML Officer UNION BANK & TRUST

Edward Starishevsky, Global Head of Sanctions & AntiCorruption AMERICAN EXPRESS (AMEX)

Erik Vingelen, Senior Vice President and BSA/AML/ OFAC Officer BANNER BANK

LEGAL E XPERTS Ryan Fayhee, Partner


Laura N. Perkins, Partner


Kerry T. Scarlott, Partner BAKER HOSTETLER

Lana Muranovic, International Trade Attorney BAKER HOSTETLER

John Boscariol, Head of International Trade & Investment Law Group MCCARTHY TÉTRAULT

Saam Youssefi-Rad, Director, Head of OFAC and Sanctions Compliance DEUTSCHE BANK

Alicia Novak, Director, Global Sanctions and AntiCorruption Program FIDELITY INVESTMENTS


Matthew Bell, Former Chief Compliance Officer & Legal Counsel ZTE CORPORATION USA

Benjamin Floyd, Senior Vice President and AML/OFAC Compliance Officer CAESARS ENTERTAINMENT CORPORATION

Ross Marrazzo, Managing Director, Chief Compliance Officer TRELIANT LLC

Liana Sebastian, Head of Global Trade Compliance GOOGLE INC.

Richard Tornberg, Group Legal Counsel Trade Compliance ERICSSON AB

Lynn Marie Van Buren, Associate General Counsel, Global Trade Compliance VERIZON

Julie Myers Wood, Chief Executive Officer


Saskia Rietbroek, Principal SANCTIONSALERT.COM

James R. Richards, Principal REGTECH CONSULTING LLC

GOVERNMENT SPEAKERS Elizabeth L.D. Cannon, Deputy Chief for Export Control and Sanctions


Christopher Conroy, Chief of Major Economic Crimes Bureau NEW YORK COUNTY DISTRICT ATTORNEY’S OFFICE

Matthew L. Levine, Executive Deputy Superintendent of Enforcement



Thomas F. Smith, Special Agent U.S. DEPARTMENT OF COMMERCE - BIS

Kelvin Ong, Chief of the Security Council’s Sanctions Branch UNITED NATIONS

WHO SHOULD ATTEND? Executives at companies who are involved in sanctions and export controls such as: • OFAC/Sanctions Compliance Officer

• Compliance Officer

• AML/BSA Officer

• Audit Manager

• Financial Crime Risk Manager

• General Counsel

• Regulatory Counsel

TOP REASONS TO ATTEND • Broaden your professional network by benchmarking with the who’s who in the industry • Avoid legal troubles and huge fines by updating your knowledge on sanctions compliance risks • Walk away with a broadened awareness of what you must do to stay out of trouble • Get experts to answer your questions directly, compare notes, and network with your colleagues.

CPE, ACAMS, & ABA CREDITS CPE CREDITS Financial Research Associates is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: The recommended CPE credit for this course is up to 6.0 credits in the following field(s) of study: Regulatory Ethics PROGRAM LEVEL: Basic ANTICIPATED CPE CREDITS: 6.0 credits RECOMMENDED FIELD(S) OF STUDY: Economics, Business Law, Finance PREREQUISITES: None ADVANCE PREPARATION: None INSTRUCTIONAL DELIVERY METHOD: GROUP LIVE LEARNING OBJECTIVES: UPON COMPLETING THE COURSE, PARTICIPANTS WILL: • Understand the challenges companies face in building a risk-averse compliance program • Learn the current risks involved when companies and banks contract for goods and services For more information, visit our website:

ACAMS CREDITS Attendees receive 9 CAMS credits for attending this event.

AMERICAN BANKERS ASSOCIATION (ABA) CREDITS ABA Professional Certifications is dedicated to promoting the highest standards of performance and ethics within the financial services industry. Sanctions Risk Management Conference has been approved for 12 CAFP, 12 CRCM credits. This statement is not an endorsement of this program or its sponsor. Certification holders must report these credits at


DAY ONE: MONDAY, OCTOBER 15 8:00 – 9:00

Registration & Networking Breakfast

9:00 – 9:15

Welcome Remarks Saskia Rietbroek, Principal SANCTIONSALERT.COM

9:15 – 9:45

Keynote Address Kelvin Ong, Chief of the Security Council’s Sanctions Branch, UNITED NATIONS

9:45 – 10:00

Morning Networking Break

10:00 – 10:45 Stirring the PEP’s Nest: Applying Global Magnitsky Sanctions to Prevent Abuse and Corruption • A rich exchange of ideas to a new sanctions regime that cuts off listed public officials and other cronies • Leveraging due diligence at the intersection of AML and sanctions to detect PEPs who may be dodging sanctions • Monitoring the behavior and transactions of oligarchs in light of this new sanctions regime • Understanding special risks when dealing with state-owned businesses Moderator: Laura N Perkins HUGHES HUBBARD & REED LLP Panelists: Tyler Hand WESTERN UNION Edward Starishevsky AMEX

10:45 – 11:00

Morning Networking Break

11:00 – 12:15 Government Panel: Enforcement of Sanctions and Regulatory Priorities • Understanding what key agencies’ priorities are, so you can prepare • What bank regulators are looking for in sanctions compliance programs • New or heightened challenges due to interagency and international cooperation • Critical changes in enforcement for sanctions program missteps Moderator: Ryan Fayhee HUGHES HUBBARD & REED LLP Panelists Christopher Conroy DISTRICT ATTORNEY’S OFFICE - NY COUNTY Elizabeth L.D. Cannon DEPARTMENT OF JUSTICE (DOJ) Matthew Levine NEW YORK DEPARTMENT OF FINANCIAL SERVICES (NYDFS) Eric Hylton IRS-CRIMINAL INVESTIGATION Thomas F. Smith U.S. DEPARTMENT OF COMMERCE - BIS

12:15 – 1:15

Networking Luncheon Sponsored by

1:15 – 2:00

Sanctions Governance Framework: Driving Compliance Through a Global Organization • Practical strategies to develop your OFAC/sanctions compliance program concepts • Comparing program structures and how they differ in impact and scope • Change the way you change: Out-of-the-box strategies for driving compliance in a dynamic geopolitical environment • Keeping costs low: A closer look at budget, streamlining resources and potential outsourcing Moderator: Saskia Rietbroek, Principal WWW.SANCTIONSALERT.COM Panelists: Richard Tornberg ERICSSON AB Kerry T. Scarlottt BAKER HOSTETLER Julie Myers Wood GUIDEPOST SOLUTIONS LLC

2:00 – 2:15

Afternoon Networking Break

2:15 – 3:00

List Matching: Best Practices for Screening and Alert Handling • Tailoring the content and application of watch-lists to the organization’s risk profile and appetite • Screening unconventional and previously overlooked areas of sanctions risk • Identifying potential gaps and inefficiencies in screening controls • Lessons learned from recent enforcement actions Moderator: Saskia Rietbroek, Principal WWW.SANCTIONSALERT.COM Panelists: Hera Smith AFEX Lynn Marie Van Buren VERIZON

3:00 – 3:15

Afternoon Networking Break

3:15 – 4:00

Case Study: Compliance with New Sanctions Targeting Terrorist Networks • This session uses audience polling and covers a case study • Hezbollah and other new terror sanctions: What are the implications for your compliance program • Multinational challenges: Dealing with diverging designations across Canada, Europe, and the Gulf • Detecting financial support networks and other conduits of funding for militant groups • Compliance with non-SDN lists associated with anti-terrorism programs, including State’s FTO Moderator: Saskia Rietbroek, Principal WWW.SANCTIONSALERT.COM Panelists: Tyler Hand WESTERN UNION

4:00 – 4:15

Afternoon Networking Break

4:15 – 5:00

Breakout Roundtables Ask practical questions and problem solve with your peers. Attendees will have a choice of moderated roundtable topics in which they can engage on more detailed discussions and benefit from a more topic-specific networking opportunity. These roundtables will take place before the networking reception on day one and after lunch on day two—giving attendees the option to choose two different topics. See page 11 for more Roundtable topics.

5:00 – 6:00

Networking Reception

RAVE REVIEWS “Great speakers, great energy & very informative.” JAMES SLATTERY, INTERNATIONAL COMPLIANCE TRAINING

“Impressive speaker panel & wealth of knowledge.” MICHELLE GALLAGHER, PCCW GLOBAL

“Many real life, practical insights into the challenges surrounding sanctions.” MARLON ORANTES, ITAU UNIBANCO S.A.

“Overall great conference; really enjoyed the private sessions.” PATRICK CAVE, GUGGENHEIM PARTNERS

DAY T WO: TUESDAY, OCTOBER 16 8:00 – 9:00

Networking Breakfast

9:00 – 9:45

Rise of the Machines: Use of AI and Emerging Tech in Your Sanctions Compliance Program • Using AI for list matching and customer due diligence • How to achieve optimized infrastructure with advanced automation tools and data analytics • Using big data to augment risk management decisions • Case study showing how a company leveraged cutting-edge technology towards better compliance Moderator: NAVIGANT Panelists: James R. Richards REG TECH CONSULTING Joe Soniat UNION BANK

9:45 – 10:00

Morning Networking Break

10:00 – 10:45 No Man is An Island: How Sanctions Compliance Fits in with AML, Compliance and the Business • How functions work together throughout procurement, compliance and sales • People – processes – software: Coherent deployment and overcoming operational silos • How to achieve management buy-in, and determine program responsibility in business lines? Moderator: Saskia Rietbroek, Principal WWW.SANCTIONSALERT.COM Panelists: Sonia Desai CHARLES SCHWAB Saam Youssefi-Rad DEUTCHE BANK Erik Vingelen BANNER BANK

10:45 – 11:00

Morning Networking Break

11:00 – 12:00 Breakout Roundtables Spend one-on-one time in a frank discussion with an industry expert and your fellow sanctions compliance professionals, then move to a different table for a different topic. These roundtables will take place before the networking reception on day one and after lunch on day two—giving attendees the option to choose two different topics. See page 11 for more Roundtable topics.

12:00 – 1:00

Networking Luncheon

1:00 – 1:45

Customer Due Diligence: Uncovering Shell Companies to Detect Hidden Beneficial Owners • Lessons learned from enforcement actions: Role of shell companies and offshore havens in sanctions busting • FinCEN’s CDD rule and how to use it to enhance your OFAC program • Using company registers, search engines, the “invisible web” and much more. • OFAC’s 50% rule and UBOs: How far should you go? Moderator: KHARON Panelists: Alicia Novak FIDELITY INVESTMENTS James R. Richards REG TECH CONSULTING Joe Soniat UNION BANK

1:45 – 2:00

Afternoon Networking Break

2:00 – 2:45

Performing Risk-Based Metrics in Auditing the OFAC/Sanctions Compliance Programs • Aligning audits to OFAC/sanctions risks • Functional roles in the auditing process (business units, audit, legal, compliance) • Metrics: How to measure the effectiveness and consistency of your audit. • Reporting the results of your review Moderator: Ross Marrazzo TRELIANT Panelists: Lynn Marie Van Buren VERIZON Brenda Perrotti PNC BANK

2:45 – 3:30

Crisis Exercise This session is not for the faint-of-heart: Here you can test your ability to be cool under fire. The “what would you do if….” exercises have been designed to put you in the shoes of a real-life OFAC/sanctions risk management disaster, as it unfolds. Participants will face dilemmas and have to make critical decisions any organization faced with a crisis will have to make. After this exercise, you’ll understand the importance of planning in advance: You’ll never want to be caught unprepared again. Moderator: Saskia Rietbroek, Principal WWW.SANCTIONSALERT.COM Panelists: Richard Tornberg ERICSSON AB Matthew Bell FORMERLY ZTE CORPORATION, USA Edward Starishevsky AMEX


End of Conference


Breakout Roundtables:

1 2 3 4 5 6

Preparing for a U.S. Federal Bank Examiners Examination Focused on OFAC Compliance • •

Steps a bank can take in advance to optimize the progress of an OFAC regulatory examination. Learn what happens when the regulator arrives, how to handle questions, and how to document the examination Important tips from the “rule book” of various regulators

Moderator Day 1 & 2: Sonia Desai, Charles Schwab

Dealing with Sanctions/Export Controls Investigations, Look-backs and Dos and Don’ts of Voluntary Self-disclosures • • •

Putting your plan in place before receiving the regulator’s call Preparing your team, including communications protocols Proper handling of subpoenas, and document requests Moderator Day 1: Julie Myers Wood, Guidepost Solutions LLC Moderator Day 2: Maria Assusa, ManTech International Corporation

Developing and Maintaining an OFAC/Sanctions Risk Assessment • •

Identifying vital risk factors related to customers and products Assessing obvious and less-obvious country risks, including contagion risks when located next to sanctioned nations Understanding the role of business departments in assessing and maintaining risk

Moderator Day 1 & 2: Erik Vingelen, Banner Bank

Navigating Iran Sanctions • • • •

Navigating the Iranian Revolutionary Guards Corp, conducting CDD and restricted party screening When a transaction is permissible for Iran, how does a company get paid for their products/services? General License H—when does a subsidiary qualify to use this license from a practical standpoint? Preventing diversion: what do you need to do? Moderator Day 1 & 2: Liana Sebastian, Google, Inc

Managing Third Party Sanctions Risk • • •

Brave new ideas to manage your vendor relationship Novel ways of problem solving while staying clear of sanctions risks Data management controls and effective monitoring tools for third, fourth, and fifth parties Moderator Day 1 & 2: Richard Tornberg, Ericsson AB

Russia, Sectoral Sanctions and Complex Non-List-Based Regimes • • • •

Russia case studies, covering OFAC’s oligarch list and other challenges Practical considerations when dealing with “new debt” Venezuela and business dealings with PdVSA How to remain compliant with new secondary sanctions under CAATSA Moderator Day 2: Lana Muranovic, Baker Hostetler

7 8 9 10



Complying with New York’s Part 504 • • •

Learn how OFAC and other lists are to be screened and how transactions should monitored. What can you can do to avoid personal liability Find out if other regulators also move to a more progressive approach to financial crime regulation Moderator Day 1 & 2: Saam Youssefi-Rad, Deutsche Bank

Complying with Canada’s Sanctions Regime • • •

Adjusting sanctions management policies to address new Canadian developments Managing sanctions oversight to address cross-border regulatory conflicts Translating the latest resolutions into a solid business action plan Moderator Day 1 & 2: John Boscariol, McCarthy Tétrault

Sanctions Compliance in Securities Broker-Dealers, Capital Markets and Asset Management Firms • • •

Sanctions considerations specific to financial institutions, with a focus on asset management and brokerage firms Sanctioned Securities: How brokerage and asset management firms must adjust to changing Russia and Venezuela sanctions How to make risk-based decisions and develop a sanctions compliance program that is both cost-effective and reasonably tailored to your firm’s risk Moderator Day 1 & 2: Alicia Novak, Fidelity Investments

Sanctions Challenges in the Asian market • • •

Ramifications of expanded sanctions on North Korea and how to continuously reassess your riskbased sanctions compliance in the region How to fully incorporate evolving global economic sanctions restrictions on North Korea Compliance landmines when doing business with Chinese banks and counterparts Moderator Day 1 & 2: Matthew Bell, Formerly ZTE Corporation, USA

Corporations and Exporters Table: Elements of an Effective Export Compliance Program • • • •

Lessons learned from enforcement actions against telecom, oil and gas, infrastructure and engineering companies How to stay compliant with sanctions/export controls and work with your banks so you can get paid for products/services Compliance with trade sanctions that prohibit trade in certain goods from affected countries Deemed exports, dual use, and other key risks affecting global exporters

Think Like The Bad Guys • • •

Renamed vessels, shell companies, stripping payment messages: The best way to learn how sanctions evaders do it is trying to design your own sanctions busting scheme. Brainstorm and design a method that outwits law enforcement and compliance officers. The next step then is discussing with your peers what you as an institution should do to fight this scheme * program is subject to change


PRINCE TON CLUB OF NEW YORK 15 W 43 Street New York, NY 10036 (212) 596-1200 If you require overnight accommodations for this conference, please contact any of the following nearby hotels to check their best available rate over the conference time frame. Please note that we have not negotiated rates with any of these hotels. Please note The Princeton Club has a “Smart Casual” dress code. For full Dress Code details, please visit their website at


PRICING STANDARD RATE SanctionsAlert/ComplianceWeek Member


Internal Practitioner


Government/Non Profit


Vendor/Consultant/Law Firm



20% OFF


Group discounts cannot be issued retroactively. In order to secure a group discount, please call one of the following: Kathie Eberhard at (704) 341-2439 Alexander Garcia: (786) 393-7840 John Voss: (305) 491 7159

Refunds & Cancellations For information regarding refund, complaint and/or program cancellation policies, please visit our website:

Register Online


Click here

Wilmington FRA 3420 Toringdon Way, Suite 240

Call (704) 341-2439 or (786) 393-7840

Charlotte, NC 28277 Make checks payable to Wilmington FRA and please write C107 on your check.

THE CONFERENCE ORGANIZER provides authoritative and objective guidance, and practical training to corporations, financial institutions, lawyers, and others on the requirements of and compliance with economic sanctions and export controls imposed by the United States, United Kingdom and other governments throughout the world, as well as by the United Nations, and European Union. Visit for information about membership, events and training.

Compliance Week, published by Wilmington plc, is an information service on corporate governance, risk and compliance that features weekly electronic newsletters, a bimonthly print magazine, proprietary databases, industry-leading events, and a variety of interactive features and forums. Founded in 2002, Compliance Week has become the premier GRC resource for public companies and the organizations that support them. Our magazine, website, electronic newsletters, databases, live and virtual events are leveraged by tens of thousands of financial, legal, audit, risk and compliance executives.

Foundation Research Associates, formerly Financial Research Associates, provides the financial community with access to business information and networking opportunities. Offering highly targeted conferences, FRA is a preferred resource for executives and managers seeking cutting-edge information on the next wave of business opportunities. Please visit for more information on upcoming events.

SPONSORSHIP & EXHIBIT OPPORTUNITIES Enhance your marketing efforts through sponsoring a special event or exhibiting your product at this event. We can design custom sponsorship packages tailored to your marketing needs, such as a cocktail reception or custom-designed networking event. To learn more about sponsorship opportunities, please contact Alex Garcia from SanctionsAlert at (786) 393-7840 or, or Doug Juenemann from Compliance Week at (617) 570-8610 or

PRESENTING SPONSORS In a world where change is certain, experience is the best protection. Guidepost Solutions offers global investigations, compliance, monitoring, and security and technology consulting solutions for clients in a wide range of industries. Our expert team provides leadership and strategic guidance to address critical client needs across the globe. Guidepost Solutions is a global team of investigators, experienced security and technology consultants, and compliance and monitoring experts. We provide security, investigative, compliance and monitoring leadership for critical client needs. As trusted partners for our high-profile clients in a wide range of industries across the globe, we survey and analyze industries in order to guide solutions. We built our brand on the collective strength, experience and reputation of individual parts and serve as an established source of protection, strategic guidance and leadership for our clients. Experience guides us. Solutions define us. Hughes Hubbard & Reed LLP is an international law firm with a relentless focus on providing quality service to our clients and delivering successful results in the most complex cross-border matters and disputes. With a powerful combination of scale and agility, we offer clients innovative and effective solutions, while remaining flexible to adapt to their needs and market developments. Known for a collaborative culture, Hughes Hubbard has a distinguished history dating back more than a century. Our lawyers advise clients across the globe in matters involving anti-corruption, sanctions, export controls, and anti-money laundering among other sensitive government and regulatory engagements. We design and implement compliance programs, conduct internal investigations, represent companies before the Department of Justice alongside other domestic and international regulators, serve as designated compliance monitors, and counsel companies subject to postresolution obligations. Offering the full range of trade compliance advice, our Sanctions, Export Controls & Anti-Money Laundering group represents clients in disclosures, enforcement actions, and authorizations involving the Commerce, State and Treasury Departments. We advise clients on licensing, commodity jurisdiction and classification issues, compliance with regulations governing the transfer of technology to foreign nationals, due diligence in connection with mergers and acquisitions, and audits. Recognized as one of the top firms for client service, BakerHostetler is a leading national law firm that helps clients around the world address their most complex and critical needs. With five core national practice groups – Business, Employment, Intellectual Property, Litigation and Tax – the firm has more than 940 lawyers located in 14 offices coast to coast. Our international trade practice is recognized by leading legal rating groups, including Chambers Global, Chambers USA and Legal 500, with members of our international trade group providing advice to clients with respect to export controls and economic sanctions compliance, foreign investment in the United States, and trade remedies and trade policy matters and disputes. BakerHostetler is also widely regarded as having one of the country’s top 10 tax practices, a nationally recognized litigation practice, an award-winning data privacy practice, and an industry-leading business practice. The firm is also recognized internationally for its groundbreaking work recovering more than $13 billion in the Madoff Recovery Initiative, representing the SIPA Trustee for the liquidation of Bernard L. Madoff Investment Securities LLC. Visit Agile, innovative, and unrivaled anywhere in the marketplace, Thomson Reuters Risk Management Solutions help you go beyond mere risk avoidance and turn regulatory complexity into business opportunity. From regulatory change management to customer and third party risk management to compliance training, Thomson Reuters can help you pro-actively create and sustain a culture of compliance, and build a reputation for consistently driving the best behavior and performance from your people and operations. Navigant Consulting, Inc. (NYSE: NCI) is a global professional services firm that helps clients take control of their future. We combine our in-depth knowledge of payer operations and regulatory requirements with exceptional data analytics, legal research, and auditing skills to offer solutions and deliver powerful results. From complex managed care regulations, to mock audits and organizational structure, we help the nation’s payers meet government requirements and protect enterprise value. For more information, visit

LUNCHEON SPONSOR Treliant’s trusted advisory services focus on meeting the growing needs of our clients in the compliance, risk management, and operational landscape. As a privately-owned firm of leading professionals from industry and government, we help bankers, lenders, mortgage and brokerage companies, and FinTech firms grow and serve consumer, small business, and capital markets clients while navigating the changing policies, rules, and agencies influencing financial services providers. We focus on the industry’s most pressing concerns, including consumer compliance, mortgage operations, financial crimes, financial markets conduct and compliance, fair lending, litigation support, and operational risk. We serve clients from Main Street to Wall Street and across the globe, often in partnership with premier law firms. Our firm continues to grow in the service of our clients, with headquarters in Washington, DC and offices in Dallas and New York. For more information, visit www.

EXHIBITOR SPONSOR Safe Banking Systems, part of Accuity, provides innovative anti-money laundering and compliance solutions that enable institutions to identify, assess and manage enterprise risk. SBS solves key Know Your Customer, Customer Due Diligence and Enhanced Due Diligence issues. The patented exposure ranking and probability scoring in SAFE Advanced Solutions Visual Intelligence Platform ÂŽ brings greater intelligence for entity resolution to clients worldwide.

Sanctions Risk Management Conference [C107]  

A practical guidance for sanctions and export compliance. Current tumultuous activity in economic sanctions and export controls compliance a...

Sanctions Risk Management Conference [C107]  

A practical guidance for sanctions and export compliance. Current tumultuous activity in economic sanctions and export controls compliance a...