Today, as the world is reeling from the healthcare and economic crisis wrought by the rapidly developing COVID-19 epidemic, the United States stands at the brink of a life-and-death trade policy decision – should we limit the export of medical devices and protective equipment needed to save lives, or keep our borders open? In recent days some of my legal colleagues have done excellent practical work summarizing the restrictions some countries are introducing on export of medical devices and protective … Read More

Much already has been written by my colleagues about the Office of Foreign Assets Control (“OFAC”) Framework for Compliance Commitments, which was published on May 2, 2019.  Very briefly, the Framework provides OFAC’s expectations that sanctions compliance programs (SCP), should include at least five essential components of compliance: (1) management commitment; (2) risk assessment; (3) internal controls; (4) testing and auditing; and (5) training I think it was an excellent development that OFAC, which generally is not known for being … Read More

As I embark on the exciting journey of running my own trade law practice, I am thinking about the issues that are most likely to be on top of mind for you – fellow legal and trade compliance professionals. This is why I decided to name this blog Thinking Trade. Here I plan to periodically highlight and analyze regulatory developments and trends that are (or should be) high on the minds of people charged with keeping their companies’ cross-border trade … Read More