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ICC Institute of World Business Law Task Force on Compliance Has Released a Guide on Sanctions for Small and Medium-Sized Enterprises (SMEs)

December 21, 2022

The guide focuses on trade sanctions and trade-control compliance in SMEs.

In particular, the guide provides:

  • Definition and classification of trade sanctions.

  • Main impacts of sanctions on SMEs, including the impact on commercial transactions, obtaining financing, exporting and importing goods, services or technology, etc.

  • Recommendations for SMEs on measures to avoid violations of trade-compliance requirements and to mitigate penalties in the event of an actual violation of sanctions (risk assessment, due diligence, sanctions compliance policy, internal investigation and self-reporting).

  • Sources on sanctions restrictions:

> OFAC sources: Sanctions search; Consolidated sanctions list

> EU sources: Sanctions map

> UK sources: UK sanctions list; Office of Financial Sanctions Implementation

> UN sources: Security Council, Consolidated list search

> Sources on Russia sanctions: Correctiv, Sanctions tracker; Castellum, Sanctions dashboard; Al Jazeera, List of sanctions on Russia after invasion

  • Sources on guidelines about sanctions compliance policies.

The Guide is available at the following link