Are You Confident About Who Are You Doing Business With? Practical Strategies to Ensure Robust Due Diligence and Screening Programs

September 25, 2018 3:45pm

Selena Garreaud
Director, Export Controls and Compliance
C Series Aircraft Limited Partnership - Airbus Bombardier

Susan M.C. Kovarovics
Bryan Cave Leighton Paisner LLP (Washington, DC)

  • Ownership screening – getting to clarity on the 50% Rule
  • Screening benefits and tradeoffs
  • Going beyond the SDN list – keeping abreast of newly-designated persons/companies
  • Reasonable timeframes for reviewing potential commercial partners – how far back in time is sufficient?
  • Discovering a “hit” – delineating false-positives from potential problems