Archives: Due Diligence

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Cross-post from the Trade Practitioner Blog: The Real Significance of OFAC’s Sanctions Compliance Guidance

On May 2, 2019, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) released guidance on effective sanctions compliance programs.  This guidance is useful for any company with an international supply chain, as both U.S. and foreign companies may be subject to, and at risk for violating, U.S. sanctions law.  As a recent example, e.l.f. Cosmetics … Continue Reading

Quoted in Bloomberg Law: Human Trafficking Case Could Lead to Expanded Supply Chain Liability

In Ratha v. Phatthana Seafood Co. Ltd., Cambodian plaintiffs sued various companies under the Trafficking Victims Protection and Reauthorization Act (TVPRA), alleging that the companies benefitted from human trafficking in the shrimp and seafood industries in Thailand. A California district court found that the claims against certain defendants failed because those companies did not knowingly participate in or benefit from human trafficking; that decision is now on … Continue Reading

Quoted in Corporate Counsel: Lessons from Hobby Lobby's Settlement

Earlier this month, nationwide arts-and-crafts retailer Hobby Lobby settled with U.S. Department of Justice over allegations of smuggling cultural artifacts from Iraq.  As part of the settlement, Hobby Lobby consented to forfeiture of the artifacts and payment of $3 million.  Hobby Lobby also agreed to adopt internal policies and procedures governing its importation and purchase of cultural … Continue Reading
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