In a recent article for Global Investigations Review, Partner Rachel Alpert discussed the US Bureau of Industry and Security's new “50%” export controls rule and its significant compliance implications for businesses.
“The nice thing is that BIS worked very hard to try to align this with OFAC’s 50% rule,” said Rachel. “There’s clearly been a lot of coordination to try to make them quite aligned, and so the concept of applying this 50% standard isn't a novel concept, since companies need to do it on the sanctions front anyway.”
Rachel emphasized the importance of proactive compliance given the enforcement risks: "If you aren't sure about your customer list and your practices in place to ensure compliance, it's important to pause and make sure that you do have the systems in place—that you don't have an inadvertent violation here—because it's entirely possible for BIS to enforce."
As Co-Chair of Jenner & Block’s National Security and Crisis Practice, Rachel guides multinational companies and institutions through the complex landscape of US sanctions, export controls, and national security regulations.
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