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By Nessym Jules TIR, Avocat/Partner, Global Compliance Investigations, Wolff Partners SCS, Attorneys at law
In October 2023, we published an article on the European Commission's guide for European operators aimed at preventing and limiting the risks of circumvention of economic sanctions against Russia. This guide highlighted the need to understand, identify, and assess the potential risks of sanctions circumvention.(1)
The European Commission’s guide specified that operators should refine the typologies of vulnerabilities in order to avoid the export of products to Russia via third countries.
It offered an anthology of good practices aimed at clarifying, in concrete terms, the right questions to be asked in the...
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