Country of Origin and Trade Sanctions
|
|
- Melanie Phelps
- 6 years ago
- Views:
Transcription
1 Country of Origin and Trade Sanctions Mini Summit XXIII: Global Compliance Update 14 th Annual Pharmaceutical Regulatory and Compliance Congress Best Practices Forum 29 October 2013 Washington, DC
2 Information in this presentation represents the presenter s opinions and recommendations and thus, may or may not be aligned with his or her company s views 1
3 COUNTRY OF ORIGIN 2
4 Substantial Transformation The country of origin is that in which ingredients are substantially transformed into: a new and different article of commerce with a name, character, or use distinct from that of the ingredients from which it was transformed. Generally: API Source Country: Single API, simple manufacturing Manufacturing Country: Single API, complex manufacturing Multiple API, regardless of manufacturing complexity This rule is the same as applied for product marking, tariff, and customs entry purposes Different standards apply for other purposes (e.g., BAA, FDA place of final manufacture ) 3
5 Trade Agreements Act (TAA) Allows the purchase of goods from: The U.S. Designated Countries Designated Countries Countries that are members of the World Trade Organization (WTO), Government Procurement Agreement (GPA), or have a bilateral Free Trade Agreement (FTA) with the U.S. Includes: Armenia, Canada, EU, Hong Kong, Iceland, Israel, Japan, Korea, Liechtenstein, Norway, Singapore, Switzerland, Chinese Taipei, Australia, Chile, Mexico, Morocco Non-Designated Countries Notable non-designated countries include China, India, and Brazil. Purchase of goods from Non-Designated Countries is prohibited, unless the agency waives the TAA based on specified waiver grounds Does not prohibit a company from offering non-designated country products 4
6 U.S. Government Contracts Pharmaceutical companies are required to offer certain products to the U.S. government through Federal Supply Schedule (FSS) Contracts All Innovator products marketed in the U.S. and authorized generics Sales price is set, but not volumes Under FSS Contracts, products listed must have a Country of Origin (COO) of: The United States or A Designated Country If COO is not a Designated Country, the COO must be disclosed in the contract proposal The U.S. government procurement can Remove the product from the contract Grant a waiver COO for pharmaceuticals is generally determined as follows (non-preferential rules) Single Active Pharmaceutical Ingredient (API) Country where API was manufactured Multiple API Country where drug product is manufactured 5
7 Single API - Scenario 1 API Produced In Italy Drug Product Produced In Ireland Origin Determination: Made In Italy 6
8 Single API - Scenario 2 API Produced In Italy Drug Product Produced In Ireland Tabletted in Puerto Rico Origin Determination: Made In Italy 7
9 Single API / Multi-Sourcing API 1 Produced In Italy API 1 Produced In Japan Blended In Ireland Tabletted in Puerto Rico Origin Determination: Made In Italy or Japan 8
10 Multiple API API 1 Produced In Italy API 2 Produced In Japan Blended In Ireland Tabletted in Puerto Rico Origin Determination: Made In Ireland 9
11 Potential Fines and Penalties Customs Violations Inaccurate COO declaration upon importation to the U.S. Civil Penalties Fraud, Gross Negligence and Negligence Range from 20 percent of import value (or 2x duty) for negligence up to 100 percent of import value for fraud Reduced penalties for a valid Prior Disclosure of the alleged violation(s) CBP could conduct an audit Criminal Penalties One option: Fines, imprisonment for not more than two years, or both The government has other options for additional fines and terms of imprisonment Inaccurate COO marking on labels for goods imported into, or sold in the U.S. Civil CBP may assess a duty equal to 10% of the article s imported value Not considered a penalty This duty cannot be mitigated by a Prior Disclosure Criminal First Offense: Up to $100,000, imprisonment for not more than 1 year, or both Second Offense +: Up to $250,000, imprisonment for not more than 1 year, or both 10
12 Potential Fines and Penalties False Claims Act Violations Civil Penalties Treble damages, plus penalties Double damages, more likely if a case is settled rather than litigated Damage claims based on sales dollars of non-compliant products Debarment from government contracting Adverse publicity, damage to reputation Debarment from government contracting Criminal Penalties Typically flow from other charges, such as false statements 11
13 TRADE SANCTIONS 12
14 General Considerations RISKS 13
15 General Considerations UN Sanctions EU Sanctions US Sanctions 14
16 EU Sanctions: Jurisdictional Issues The EU regulations are binding on: 28 EU Member States every person that has the citizenship of a Member State every entity, group or institution incorporated under the laws of a Member State every entity, group or institution with regard to their operations within the European Union 15
17 EU Sanctions: More Than 30 Countries WTO China Cote d Ivoire Democratic Republic of Congo Egypt Haiti Moldova Montenegro Myanmar (Burma) Republic Of Guinea (Conakry) Tunisia USA (United States of America) Zimbabwe NON-WTO Afghanistan Belarus Bosnia and Herzegovina Eritrea Iran Iraq Lebanon Liberia Libya North Korea Serbia Somalia South Sudan Sudan Syria Al Qaeda Terrorist Groups (Foreign Terrorist Organisations) 16
18 Economic Sanctions Who Must Comply? A Comparison U.S. E.U. Citizens/Nationals (wherever located) Including green card holders Persons in territory Entities incorporated/doing business in territory Overseas branches of incorporated entities Overseas subsidiaries of incorporated entities Goods originating in territory Transactions through territory Cuba and Iran only 17
19 Economic Sanctions Current Sanctions Programs U.N., E.U., and U.S. Program U.N. E.U. U.S. 1 Afghanistan 2 Belarus 3 Burma/Myanmar * ** 4 Cote D Ivoire 5 Cuba*** 6 DRC (Congo) 7 Egypt 8 Eritrea 9 Former Yugoslavia/Balkans 10 Guinea 11 Guinea-Bissau 12 Iran **** 13 Iraq 14 Lebanon * Suspended except for arm embargo ** General licenses authorize most activity except with Restricted Parties / military junta / security services *** Blocking measures apply **** General licenses or exemptions authorize certain shipments of medicine and agricultural commodities 18
20 Economic Sanctions Current Sanctions Programs U.N., E.U., and U.S. Program U.N. E.U. U.S. 15 Liberia 16 Libya 17 North Korea 18 Somalia 19 Sudan **** 20 Syria ***** 21 Tunisia 22 Zimbabwe 23 Counter-Terrorist/Terrorist Financing 24 Al-Qaeda and Taliban 25 Counter-Narcotics Trafficking sanctions 26 Non-proliferation 27 Rough Diamond Trade Controls 28 Transnational Criminal Organisations **** General licenses or exemptions authorize certain shipments of medicine and agricultural commodities ***** Different license requirements for U.S. versus non-u.s. origin commodities 19
21 Economic Sanctions Most countries have one or two agencies dealing with economic sanctions Application to cross-border financial business can be complex and challenging: Country sanction programs versus targeted sanctions Differing sanctioned persons lists Differing sanctions mechanisms Blocking statutes Responsibility for administration of E.U. sanctions, including licensing, rests with the competent authority in each Member State Within each Member State, different authorities can be responsible for licensing different activities For instance, in the UK, the HM Treasury is responsible for financial sanctions and BIS is responsible for trade and export control-related issues In some cases, licenses can be granted 20
22 Compliance Programs Cross-border Compliance Need for a coordinated, consistent approach to the management of compliance. Global companies cannot focus solely on U.S. regulations Overlapping Exports Imports Sanctions AML Anti-bribery Periodic and effective risk assessments to take account of different requirements in E.U. and U.S., and cross-jurisdictional issues Organization-wide Training, Education and Awareness Ensuring compliance functions remain up to date with global developments. 21
23 Compliance Programs Establish, maintain, and regularly review policies and procedures Set corporate standards Get commitment from management Establish a team Decide on a centralized versus decentralized model Can be a mix of lawyers and compliance professionals Create a reporting chain and escalation plan Provide appropriate initial and follow-up training To the team To management and other key stakeholders Have regular meetings With the core team With the key stakeholders Keep your program up-to-date Policies and procedures Key referential or guidance documents Be proactive about assessing exposures prior to actual implementation by authorities 22
24 Compliance Programs Monitor legislation and provide regulatory updates to the team and stakeholders Responding to changes is essential Each regulatory change may require a different approach Libya was different from Syria, which is different from Iran, which is different from Belarus Have an incident response plan Determine how to deal with government filings and inquiries Interact with government regulators and maintain a regular connection, before there is an issue Conduct risk assessments Including testing of controls Communicate with your peers and industry groups
25 Penalty Structure Trade Sanction Violations OFAC Civil penalties Depends on the country (up to $65,000 per violation or same as the EAR) Strict liability Criminal penalties up to $1 million or 20 years, or both, for each violation Willful violations committed with knowledge of the law EAR Civil penalties greater of $250,000 or twice the value of the export Strict liability Criminal penalties up to $1 million or 20 years, or both Willful violations committed with knowledge of the law
26 Questions? Joshua Holzer Chief Counsel for Global Trade Pfizer Inc. 25
Convención Nacional 2014 Compliance at Schenker Group
Compliance at Schenker Group SCHENKER LOGISTICS SAU Gert Lehmann 23 de mayo 2014 Sumario Basic concepts of Compliance Code of Conduct Business Partner Compliance Export Trade control Compliance at Schenker
More informationInternational Sanctions Ramifications of Recent Legal Developments
International Sanctions Ramifications of Recent Legal Developments Peter Crowther, Partner, Dewey & LeBoeuf, London CONTENTS Role played by the United Nations EU Sanctions Applicability Enforcement Current
More informationEconomic Sanctions Procedure
Economic Sanctions Procedure Short description ArcelorMittal and its employees conduct business in more than 60 nations around the world and, accordingly, are subject to various economic sanctions laws.
More informationDoing Business with Iran: The EU Sanctions Regime
Doing Business with Iran: The EU Sanctions Regime Chamber of Commerce of Hasselt 30 March 2017 Guy Soussan and Jack Hayes Overview of Presentation 1. Basic overview of EU economic sanctions 2. EU sanctions
More informationSanctions Compliance American Petroleum Institute March 27-28, 2017
Sanctions Compliance American Petroleum Institute March 27-28, 2017 Alan Kashdan International Trade Department Hughes Hubbard & Reed LLP Page 2 I. Introduction Introduction Sanctions are very much in
More informationINTERNATIONAL TRADE RELATIONS POLICY. This policy covers the manner in which Grindrod conducts business in foreign countries.
INTERNATIONAL TRADE RELATIONS POLICY 1. OVERVIEW This policy covers the manner in which Grindrod conducts business in foreign countries. 2. SANCTIONS It is Grindrod s intention to comply with international
More informationDoing business with Iran : sanctions risks for the shipping and logistics sector
Doing business with Iran : sanctions risks for the shipping and logistics sector Gerard Kreijen & Jochen Vankerckhoven LOYENS & LOEFF 1 Contents The lifting of EU sanctions against Iran The Iran sanction
More informationLOGSTOR International Sanctions Policy
As approved by BoD on 8. May 2018 LOGSTOR International Sanctions Policy Page 1 of 6 1. Purpose and Scope National governments and international bodies may establish sanctions and export control restrictions
More informationU.S. Economic Sanctions: Current Landscape, Recent Activity, and New Developments
U.S. Economic Sanctions: Current Landscape, Recent Activity, and New Developments Speaker Meredith Rathbone Associate Steptoe & Johnson LLP, Lex Mundi member firm for Washington D.C. mrathbone@steptoe.com
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! "Global Economic Sanctions: Cross-Border
More informationGroup Sanctions Policy
Group Sanctions Policy 1. Purpose This Policy provides instruction with regards to the treatment of, and compliance with, sanctions or restrictive measures imposed on countries, territories, entities,
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! Issue Spotting International Trade
More informationArgentina Bahamas Barbados Bermuda Bolivia Brazil British Virgin Islands Canada Cayman Islands Chile
Americas Argentina (Banking and finance; Capital markets: Debt; Capital markets: Equity; M&A; Project Bahamas (Financial and corporate) Barbados (Financial and corporate) Bermuda (Financial and corporate)
More informationEconomic Sanctions: Canada s s New Compliance Minefield. John W. Boscariol
Economic Sanctions: Canada s s New Compliance Minefield John W. Boscariol jboscariol@mccarthy.ca June 13, 2011 Toronto i.e. Canada Canadian & U.S. Export Controls Workshop Growing Impact of Canadian Trade
More informationImpact of Canadian Economic Sanctions, Trade Controls and Anti-Corruption Laws on the AML Compliance Function
Impact of Canadian Economic Sanctions, Trade Controls and Anti-Corruption Laws on the AML Compliance Function ACAMS Toronto Chapter Lunch & Learn: Managing the Money Laundering Risk of Offshore Money Flows
More informationInternational Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017
International Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017 Introduction TOM CUMMINS Tom Cummins Partner T +44 (0)20 7859 1051 M +44 (0)7900 890 679 tom.cummins@ashurst.com Partner in Ashurst s
More informationGlobal Business Club of Mid-Michigan Export 201: Export Controls The Updates Government Regulations You Need to Know
Global Business Club of Mid-Michigan Export 201: Export Controls The Updates Government Regulations You Need to Know MSU Henry Center for Executive Development March 19, 2014 Jean G. Schtokal Jean G. Schtokal
More informationTaking sanctions seriously
Taking sanctions seriously Managing sanctions risks Briefing Thursday 15 th January 2015 Mark Spiers Why take sanctions seriously? Breaches are criminal offences But it is different to AML and CTF They
More informationRevision Date: New Effective Date: Current Version Approved By: Brian D. Walters, Vice-President and General Counsel
Purpose: Export controls apply to the export, re-export, or transfer of items, technology, software, and services. U.S. export control laws, including the Export Administration Act and the Export Administration
More informationSanctions and Insurance
Sanctions and Insurance Where are we and what to look out for? Presented by: John Bromley Sanctions in Canada come into force pursuant to one of three statutes United Nations Act Special Economic Measures
More informationThe Interaction of Canadian and US Economic Sanctions Against Iran and Other Countries
The Interaction of Canadian and US Economic Sanctions Against Iran and Other Countries John W. Boscariol June 14, 2016 Growing Impact of Canadian Trade Controls 1 what s driving this? since 9/11, new emphasis
More informationGreif Economic and Trade Sanctions Policy
Greif Economic and Trade Sanctions Policy Introduction Greif, Inc. and its subsidiaries, including joint venture companies (collectively, Greif ) are committed to compliance with all applicable laws, rules
More informationEconomic Sanctions Compliance Overview
Economic Sanctions Compliance Overview Last updated on April 6 th, 2011 Overview of Economic Sanctions Programs This Compliance Overview supplements and provides compliance guidance in support of ArcelorMittal
More informationSpecial Challenges in Documenting the Source of Funds for Clients from Transitional Countries
Where, Investor, Are You From? Country Specific Issues Cletus M. Weber (dl), Mercer Island, WA Doreen M. Edelman, Washington DC Robert P. Gaffney, San Francisco, CA Special Challenges in Documenting the
More informationTRENDS AND MARKERS Signatories to the United Nations Convention against Transnational Organised Crime
A F R I C A WA T C H TRENDS AND MARKERS Signatories to the United Nations Convention against Transnational Organised Crime Afghanistan Albania Algeria Andorra Angola Antigua and Barbuda Argentina Armenia
More informationDoing Business in an International World: The Importance of U.S. Export Control Compliance
Doing Business in an International World: The Importance of U.S. Export Control Compliance Presented by Patrick Egan, Esq. Nevena Simidjiyska, Esq. 1 Disclaimer Information Only (No Legal Advice!) Information
More informationBERMUDA INTERNATIONAL SANCTIONS REGULATIONS 2013 BR 14 / 2013
QUO FA T A F U E R N T BERMUDA INTERNATIONAL SANCTIONS REGULATIONS 2013 BR 14 / 2013 TABLE OF CONTENTS 1 2 3 4 5 Citation Application Publication of list of designated or listed persons constituting the
More informationExport Compliance: Sanctions, Embargos, Denied Parties
Export Compliance: Sanctions, Embargos, Denied Parties Lizbeth C. Rodriguez-Johnson Holland & Hart, LLP 555 17 th Street, Denver CO 303-295-8399 lrodriguez@hollandhart.com October 16, 2017 Copyright Holland
More informationGuidance Paper. ICC Commission on Banking Technique and Practice
Guidance Paper ICC Commission on Banking Technique and Practice Guidance Paper Guidance Paper on the Use of Sanction Clauses for Trade Related Products (e.g. Letters of Credit, Documentary Collections
More informationDetermining Source Selection with the Buy American Statute
Determining Source Selection with the Buy American Statute Breakout Session #: D12 Roy Nyquist, CPCM,CFCM, Fellow Shene Commodore, CPCM,Fellow Date: Tuesday, July 26 Time: 11:15am-12:30pm Buy American
More informationU.S. Trade Controls: Key Compliance Challenges
U.S. Trade Controls: Key Compliance Challenges Prepared for: Presented By: Peter Flanagan and John Pisa-Relli, Accenture October 16, 2017 1 What Are Trade Controls? Export controls: Restrictions on the
More informationBank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training
Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training OVERVIEW The Bank Secrecy Act, or BSA, was passed by congress in 1970. The BSA required banks to maintain records of certain
More informationPolicy on Compliance with U.S. Requirements Affecting International Persons, Countries, Organizations and Activities
Policy on Compliance with U.S. Requirements Affecting International Persons, Countries, Organizations and Activities I. Sanctions Imposed by the U.S. Government A. Countries and Programs The U.S. government
More informationWhat In-House Counsel Needs to Know about Trade Compliance
What In-House Counsel Needs to Know about Trade Compliance Randy Rucker Partner Drinker Biddle & Reath LLP Joan Koenig Counsel Drinker Biddle & Reath LLP Jennifer Quinn Associate General Counsel Omron
More informationPOLICIES AND PROCEDURES
Introduction This Policy is adopted by Paradigm to reinforce its commitment to full compliance with all laws of the United States pertaining to export controls and economic sanctions. This Policy revises
More informationImplementing an Effective Sanctions and Export Compliance Program
Implementing an Effective Sanctions and Export Compliance Program 1 MICHAEL VOLKOV THE VOLKOV LAW GROUP LLC MVOLKOV@VOLKOVLAW.COM (240) 505-1992 2 Implementing an Effective Sanctions and Export Compliance
More informationCorporate Application Form
Corporate Application Form For Internal Use Only Reference : Receipt : This application must be fully completed and duly signed in order to open an account with ActivTrades. Please contact our desk on
More informationMICHAEL RUFE EXPORT CONTROL OFFICER COORDINATOR BUREAU OF INDUSTRY AND SECURITY
MICHAEL RUFE EXPORT CONTROL OFFICER COORDINATOR BUREAU OF INDUSTRY AND SECURITY Special Agent Michael Rufe began his career with the Office of Export Enforcement (OEE) in August 1997. Prior to his time
More information- RESTRICTED PARTY SCREENING (RPS) LISTS -
- RESTRICTED PARTY SCREENING (RPS) LISTS - AUSTRALIA LISTS: APRA Disqualification Registers Australian Prudential Regulatory Authority - Disqualification Register AUSTRAC - Consolidated List AUSTRAC Consolidated
More informationUS Export Control and Non US Companies The basics of compliance
US Export Control and Non US Companies The basics of compliance Oct 3, 2008 Don Buehler Yokahama IAQG meeting 1 The Topics 1. Why should Asian & European companies care? 2. What is an Export? 3. What are
More informationSURVEY TO DETERMINE THE PERCENTAGE OF NATIONAL REVENUE REPRESENTED BY CUSTOMS DUTIES INTRODUCTION
SURVEY TO DETERMINE THE PERCENTAGE OF NATIONAL REVENUE REPRESENTED BY CUSTOMS DUTIES INTRODUCTION This publication provides information about the share of national revenues represented by Customs duties.
More informationSteel Founders' Society of America
Steel Founders' Society of America Barnes & Thornburg, LLP Karen A. McGee, Esq. Partner (202)408-6932 April 8, 2010 kmcgee@btlaw.com 1 2009 Barnes & Thornburg LLP. All Rights Reserved. This Barnes & Thornburg
More informationGlobal Overview of 2012 Pooled Funding
Global Overview of 2012 Pooled Funding CERF, CHFs and ERFs 15 February 2013 Page 0 1. Introduction This overview provides key funding information on the Central Emergency Response fund (CERF), Common Humanitarian
More informationINTERNATIONAL TRADE AND INVESTMENT
The World Trade Organization 121 The North American Free Trade Agreement 122 Canada-European Union Comprehensive Trade and Economic Agreement 123 Other Free Trade Agreements 123 Bilateral Investment Treaties
More informationCorrespondent Banking & Trade / Export Finance: New Challenges
Correspondent Banking & Trade / Export Finance: New Challenges Commerzbank at a glance Commerzbank is chosen Bank No. 1 for the German Mittelstand and is one of the leading retail and corporate financing
More informationU.S. Export Controls Frequently Asked Questions
SHEPPARD MULLIN SHEPPARD MULLIN RICHTER & HAMPTON LLP GOVERNMENT CONTRACTS & REGULATED INDUSTRIES PRACTICE OUR MISSION IS YOUR SUCCESS U.S. Export Controls Frequently Asked Questions Sheppard, Mullin,
More informationAIBA. 14 September 2010
AIBA 14 September 2010 What is OFAC? Office of Foreign Assets Control (OFAC) U.S. Department of the Treasury OFAC administers and enforces economic and trade sanctions against targeted: Foreign governments
More informationSource of wealth guidelines
Source of wealth Source of wealth guidelines Our Application forms contain a section called Source of wealth. It asks for background information to explain where the money you are using to pay your premiums
More informationANNEX 2: Methodology and data of the Starting a Foreign Investment indicators
ANNEX 2: Methodology and data of the Starting a Foreign Investment indicators Methodology The Starting a Foreign Investment indicators quantify several aspects of business establishment regimes important
More informationScale of Assessment of Members' Contributions for 2008
General Conference GC(51)/21 Date: 28 August 2007 General Distribution Original: English Fifty-first regular session Item 13 of the provisional agenda (GC(51)/1) Scale of Assessment of s' Contributions
More informationU.S. EXPORT CONTROL LAWS AND INTERNATIONAL OPERATIONS: A QUICK REFERENCE GUIDE FOR CORPORATE COUNSEL
U.S. EXPORT CONTROL LAWS AND INTERNATIONAL OPERATIONS: A QUICK REFERENCE GUIDE FOR CORPORATE COUNSEL Nelson Dong and Larry Ward Dorsey & Whitney LLP Seattle, Washington June 2015 This paper covers three
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationDirectorate C: National Accounts; prices and key indicators Unit C.3: Statistics for administrative purposes
Ref. Ares(2017)4629878-22/09/2017 EUROPEAN COMMISSION EUROSTAT Directorate C: National Accounts; prices and key indicators Unit C.3: Statistics for administrative purposes Eurostat Report on the Intermediate
More informationWhat Every LTI Dealer and Sales Agent Should Know about the U.S. Export Controls. March 2014
What Every LTI Dealer and Sales Agent Should Know about the U.S. Export Controls March 2014 Why do we have export controls? Export control laws principal objective: To promote national security interests
More informationU.S. RESTRICTIONS ON OVERFLIGHTS AND AIR TRANSPORTATION SERVICES. By Lonnie Anne Pera
U.S. RESTRICTIONS ON OVERFLIGHTS AND AIR TRANSPORTATION SERVICES (April 2017) By Lonnie Anne Pera Over the years, the United States has restricted travel, travel services, and transportation services.
More informationSource of wealth guidelines
For use in Singapore only Source of wealth guidelines Our application forms contain a section called source of wealth which needs to be completed to give us information on where the income your client
More informationCompliance and New Legislation in Delaware and Beyond. Sponsored By: Wolters Kluwer. CT Corporation
Compliance and New Legislation in Delaware and Beyond PRESENTED BY: ALAN STACHURA SENIOR MANAGER GOVERNMENT RELATIONS Sponsored By: Agenda OFAC & Compliance 2018 in Delaware Delaware Updates Hot Topics
More informationCounterterrorism and Humanitarian Engagement Project
Counterterrorism and Humanitarian Engagement Project OFAC Licensing Draft Background Briefing March 2013 *This publication is part of a research and policy project and reflects academic research and consultations
More informationUkraine. WTS Global Country TP Guide Last Update: December Legal Basis
Ukraine WTS Global Country TP Guide Last Update: December 2017 1. Legal Basis Is there a legal requirement to prepare TP documentation? Since when does a TP documentation requirement exist in your country?
More informationINTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT BOARD OF GOVERNORS. Resolution No. 612
INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT BOARD OF GOVERNORS Resolution No. 612 2010 Selective Increase in Authorized Capital Stock to Enhance Voice and Participation of Developing and Transition
More informationIO_S104 Rev. 1 dtd. 15/07/2018 Page 1 of 6
Integrated Business Management System Compliance with United States export and trade laws IO_S104 Rev. 1 dtd. 15/07/2018 Page 1 of 6 0 Purpose... 2 1 References... 2 2 Definitions... 2 3 Responsibilities...
More informationTotal Imports by Volume (Gallons per Country)
1/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 11/2016 11/2017 % Change 2016 2017 % Change MEXICO 50,994,409 48,959,909 (4.0)% 631,442,105 657,851,150 4.2 % NETHERLANDS 9,378,351 11,903,919
More informationAML and U.S. Sanctions Laws Recent Developments Anti-Money Laundering Seminar January 24, 2018 Beijing, PRC
AML and U.S. Sanctions Laws Recent Developments Anti-Money Laundering Seminar January 24, 2018 Beijing, PRC Joseph T. Lynyak III, Partner, Washington, DC Lanier Saperstein, Partner, New York Agenda Overview
More informationCriminal Issues Arising in International Trade: Canada s Economic Sanctions
Criminal Issues Arising in International Trade: Canada s Economic Sanctions 20 th Transnational Crime Conference IBA Criminal Law Committee & IBA Business Crime Committee Lisbon, Portugal John W. Boscariol
More informationWelcome to Baker McKenzie Stockholm Fifth Annual Trade Day. 7 November 2017
Welcome to Baker McKenzie Stockholm Fifth Annual Trade Day 7 November 2017 Sanctions Update Alison Stafford Powell and Olof Johannesson 4 Alison J. Stafford Powell Partner Baker McKenzie Palo Alto CA
More informationWritten evidence submitted by the British Retail Consortium (BRC) (TB10)
Written evidence submitted by the British Retail Consortium (BRC) (TB10) Executive Summary Key BRC priority on Trade Bill is to ensure the transitioning of more than 60 free trade and associated bilateral
More informationTotal Imports by Volume (Gallons per Country)
10/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 08/2017 08/2018 % Change 2017 2018 % Change MEXICO 67,180,788 71,483,563 6.4 % 503,129,061 544,043,847 8.1 % NETHERLANDS 12,954,789 12,582,508
More informationGift Card. Cardholder Frequently Asked Questions. July 2010 FQG20102
Gift Card Cardholder Frequently Asked Questions Gift Card (1) Where can I use my card? Your card may be used anywhere debit cards are accepted. The brand marks on your card indicate where the card is accepted
More informationTotal Imports by Volume (Gallons per Country)
11/2/2018 Imports by Volume (Gallons per Country) YTD YTD Country 09/2017 09/2018 % Change 2017 2018 % Change MEXICO 49,299,573 57,635,840 16.9 % 552,428,635 601,679,687 8.9 % NETHERLANDS 11,656,759 13,024,144
More informationEconomic Sanctions Compliance Overview
Economic Sanctions Compliance Overview This Compliance Overview supplements and provides compliance guidance in support of ArcelorMittal s Economic Sanctions Guidelines. The first part of this overview
More informationTotal Imports by Volume (Gallons per Country)
3/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 12/2017 12/2018 % Change 2017 2018 % Change MEXICO 54,169,734 56,505,154 4.3 % 712,020,884 773,421,634 8.6 % NETHERLANDS 11,037,475 8,403,018
More informationTotal Imports by Volume (Gallons per Country)
12/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 10/2017 10/2018 % Change 2017 2018 % Change MEXICO 56,462,606 60,951,402 8.0 % 608,891,240 662,631,088 8.8 % NETHERLANDS 11,381,432 10,220,226
More informationTotal Imports by Volume (Gallons per Country)
2/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 12/2016 12/2017 % Change 2016 2017 % Change MEXICO 50,839,282 54,169,734 6.6 % 682,281,387 712,020,884 4.4 % NETHERLANDS 10,630,799 11,037,475
More informationTotal Imports by Volume (Gallons per Country)
2/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 11/2017 11/2018 % Change 2017 2018 % Change MEXICO 48,959,909 54,285,392 10.9 % 657,851,150 716,916,480 9.0 % NETHERLANDS 11,903,919 10,024,814
More informationTHE WORLD ISN T FLAT MANAGING TRADE RISK
June 2010 THE WORLD ISN T FLAT MANAGING TRADE RISK Global Reach of U.S. Export Controls Bruce Jackson, Export Practice Leader, Trade Management Consulting J.P. M O R G A N P R O P R I E T A R Y Contents
More informationAnti-Money Laundering Compliance Issues
Anti-Money Laundering Compliance Issues 4th Annual Continuing Professional Development Event November 12, 2015 Presented by: Victoria Stuart Peter Moffatt 1 Introduction Compliance regime for reporting
More informationTotal Imports by Volume (Gallons per Country)
10/5/2017 Imports by Volume (Gallons per Country) YTD YTD Country 08/2016 08/2017 % Change 2016 2017 % Change MEXICO 51,349,849 67,180,788 30.8 % 475,806,632 503,129,061 5.7 % NETHERLANDS 12,756,776 12,954,789
More informationBribery and Corruption
Bribery and Corruption The FCPA, UK Bribery Act, and Other Anti-Corruption Measures 2018 Association of Certified Fraud Examiners, Inc. Introduction The FCPA and the UK Bribery Act are the two premier
More informationISO Anti-bribery management system standard
ISO 37001 Anti-bribery management system standard Neill Stansbury Chair: ISO 37001 Project Committee Co-founder & Director: GIACC www.giaccentre.org 2016 GIACC 1 Bribery is a significant business risk
More informationDoing business in Iran EHSAN HOSSEINZADEH, ATTORNEY AT LAW & PARTNER AT EDUCATED LAWYERS LAW FIRM
Doing business in Iran EHSAN HOSSEINZADEH, ATTORNEY AT LAW & PARTNER AT EDUCATED LAWYERS LAW FIRM Corporate structure in Iran Limited Liability Private Joint Stock Public Joint Stock Foreigner can possess
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationPROHIBITED BUSINESS PRACTICES POLICY
PROHIBITED BUSINESS PRACTICES POLICY It is the policy of LiquidPower Specialty Products Inc. ( LSPI ) and its subsidiaries and joint ventures (collectively, the LSPI Companies ) to strictly comply with
More informationide: FRANCE Appendix A Countries with Double Taxation Agreement with France
Fiscal operational guide: FRANCE ide: FRANCE Appendix A Countries with Double Taxation Agreement with France Albania Algeria Argentina Armenia 2006 2006 From 1 March 1981 2002 1 1 1 All persons 1 Legal
More informationInternational Trade Controls
International Trade Controls Covington & Burling LLP has long been a leading firm in advising and assisting clients with legal problems arising from a variety of U.S. trade control measures administered
More informationManaging Trade Compliance risk in Global Trade
Managing Trade Compliance risk in Global Trade TEID, Ethics and Reputation Society Hidiv Kasrı, Istanbul, February 20, 2018 Agenda for our discussion 1. What is Trade Compliance? 2. Understanding the risk!
More informationWORLD HEALTH ORGANISATION MONDIALE. NINTH WORLD HEALTH ASSEMBLY Jg? \ A9/P&B/19 ^! fr t 15 May 1956 Agenda item 6.5 îj. L,, л
WORLD HEALTH ORGANISATION MONDIALE ORGANIZATION DE LA SANTÉ NINTH WORLD HEALTH ASSEMBLY Jg? \ A9/P&B/19 ^! fr t 15 May 1956 Agenda item 6.5 îj. L,, л Q-u L. * ORIGINAL: ENÓLISH REVIEW AND APPROVAL OF THE
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationBilateral agreements on investment promotion and protection
Bilateral agreements on investment promotion and protection Country Date Signed Entry into force South Africa 26 April 2005 - Albania 30 October 1993 - Algeria 7 July 2006 - Germany 20 December 1963 6
More informationSlovakia Country Profile
Slovakia Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Slovakia EU Member State Double Tax Treaties Yes With: Australia Austria Belarus
More informationIntroduction UC Compliance & Audit Symposium. Objective: outline key considerations in establishing and maintaining international activities
2013 UC Compliance & Audit Symposium Matt Hicks, Systemwide Audit Director (Moderator) Rowena R. Manlapaz, Senior Counsel, UC Office of the General Counsel Ellen R. Auriti, Senior Counsel, UC Office of
More informationAPA & MAP COUNTRY GUIDE 2018 UKRAINE. New paths ahead for international tax controversy
APA & MAP COUNTRY GUIDE 2018 UKRAINE New paths ahead for international tax controversy UKRAINE APA PROGRAM KEY FEATURES Competent authority Relevant provisions Types of APAs available Acceptance criteria
More informationWith many multi-million. Insights. Peace of mind. Negotiating the sanctions regulatory maze: Key jurisdictions to consider
Peace of mind Negotiating the sanctions regulatory maze: Key jurisdictions to consider Insights With many multi-million dollar lawsuites plaguing even the biggest global companies, understanding the regulatory
More informationLEGAL CONSIDERATIONS FOR EXPORTERS
LEGAL CONSIDERATIONS FOR EXPORTERS November 17, 2016 Adam R. Konrad 414-298-8737 akonrad@reinhartlaw.com 1000 North Water Street, Suite 1700, Milwaukee, WI 53202 www.reinhartlaw.com Adam R. Konrad is a
More informationFinancial Sanctions in the Funds Sector and EMIR Update
CPD Code: 2017-0669 Financial Sanctions in the Funds Sector and EMIR Update Niamh Lynn, Manager of EMIR Unit, Securities and Markets Supervision Division Central Bank of Ireland Conor O Donnell, Senior
More informationStephen Hall Outreach & Educational Services Bureau of Industry and Security PRI-NADCAP Conference October 23, 2017
Stephen Hall Outreach & Educational Services Bureau of Industry and Security PRI-NADCAP Conference October 23, 2017 Do I Need an Export License? Introduction to Export Controls under the Export Administration
More informationMaritime Law Association of Singapore U.S. Embargoes and Sanctions Knowing and Navigating the Changing Field in International and Cross-Border Deals
Maritime Law Association of Singapore U.S. Embargoes and Sanctions Knowing and Navigating the Changing Field in International and Cross-Border Deals June 15, 2016 Ron Oleynik (202) 457-7183 ron.oleynik@hklaw.com
More informationU.S. Export Controls: Understanding Your Obligations Practical Tips and Traps
Presented by: U.S. Export Controls: Understanding Your Obligations Practical Tips and Traps Lindsay B. Meyer, Ezsq. American Petroleum Institute March 31, 2014 Robert G. Kreklewetz Millar Kreklewetz LLP
More informationGlobal Export Controls Webinar: A Snapshot of the U.S., EU and PRC
Global Export Controls Webinar: A Snapshot of the U.S., EU and PRC July 9, 2009 Presenters: Jerome J. Zaucha Vanessa C. Edwards Dr. Christian Hullmann Robert V. Hadley Yujing Shu Vita Xu Agenda Introduction
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Czech Rep. EU Member State Yes Double Tax With: Treaties Albania Armenia
More informationSTATISTICS ON EXTERNAL INDEBTEDNESS
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT PARIS BANK FOR INTERNATIONAL SETTLEMENTS BASLE STATISTICS ON EXTERNAL INDEBTEDNESS Bank and trade-related non-bank external claims on individual borrowing
More information