Signed in as:
Signed in as:
For decades, compliance with, and enforcement of, export controls and sanctions has been predominantly a reactive mission. The illicit acquisition networks sponsored by certain foreign countries, terrorist organizations, and organized criminal syndicates have exploited industry and threatened economic and international security.
Historically, compliance with regulations has been legal based. The aforementioned entities have learned, over the years, how to circumvent the laws, which has resulted in the growth of illicit acquisition.
As government promotes a risk-based approach to compliance, the need to understand illicit acquisition increases exponentially, and based on that, how to effectively identify red flags, how to mitigate them, and how to focus on the critical risk areas inherent in a company's business operations.
With decades of experience in countering illicit acquisition, regulating and enforcing export controls and sanctions internationally, and assisting companies to comply with the laws, the founding partners determined to establish a network of sanctions and export control societies throughout the U.S., Europe, and in the future, Asia.
In early 2022, our founder approached the Swedish Export Control Society and asked the Board of Directors to assist in establishing the network of European Sanctions and Export Control Societies. Upon agreement, the Swedish Society provided needed guidance to help in establishing the Finnish Sanctions and Export Control Society.
Solid Plan Consulting, FTI Consulting, and Orrick, Herrington & Sutcliffe, dedicated significant resources to create the first society in the network with the assistance of Patria Group, Global Trade Compliance Solutions, Beweship, Borenius, Bock Trade Law, and Miltton USA.
Since the establishment of the Finnish Society, and largely due to its success, the network of societies continues to grow throughout Europe, the United States, and across the Northern Hemisphere.
Our goal is to coordinate a risk, threat and legal-based approach to complying with multilateral sanctions and export control regulations across all societies and to assist companies and governments in working together to enhance global trade compliance. We will:
The network of societies will coordinate and advocate for members by:
The network of societies will provide training opportunities, to include:
Focusing solely on compliance with the regulations can often be a check-in-the-box exercise missing the underlying reasons why export controls and sanctions exist. Adversarial governments study laws and have learned how to circumvent them. A solely reactive and legal-based approach to compliance can cause a wide variety of risk to a company.
A risk-based approach focuses on the risks factors inherent in conducting global trade, identifying red flags, and ensuring an organization knows its supply chain, customers, and customer's customers.
A threat-based approach focuses on the threats posed to industry by adversarial foreign government's, terrorist organization's, and organized crime's illicit acquisition programs. When comparing the priorities of these entities to a company's products and services, industry can allocate limited resources to critical threats and protect its people, products, services, and reputation.
Historically, industry and government have maintained reactive approaches to compliance and enforcement. Government enforcement is the last line of defense in ensuring compliance with export controls and sanctions; however, reactive enforcement inherently means government is responded to illegal and illicit activity that has already occurred.
Industry is the first line of defense in sanctions and export controls. Industry is uniquely situated to detect and identify threats, risks, and nefarious activities. By making industry aware of the threats posed by illicit acquisition networks, companies can take a proactive approach to protect themselves and international security.
Understanding how to align limited resources to address critical risk areas affecting a company, using all methods of legal, risk, and threat-based compliance while balancing a proactive and reactive approach.