Workshop A — The Evolution of Third-Party, End-User and End-Use Due Diligence: Strengthening Screening, Monitoring and Supply Chain Controls in a Higher-Risk Environment
As third-party and supply chain risk becomes increasingly complex, how should exporters strengthen their approach to vetting suppliers, freight forwarders, distributors, customers, end-users and end-uses? This workshop will examine current best practices for conducting effective due diligence, identifying compliance red flags, monitoring evolving ownership and affiliation risks, and building defensible screening processes across increasingly complex global supply chains.
Topics will include:
- Keeping due diligence, screening and monitoring protocols aligned with evolving BIS, OFAC and GAC expectations
- Navigating expanding restricted-party, ownership and affiliation risks and determining when screening must go beyond named entities
- Drawing practical lessons from BIS and partner-agency enforcement guidance and actions to identify emerging areas of regulatory scrutiny
- Identifying end-use and end-user risks requiring heightened attention, including sensitive technologies, country-specific controls and high-risk jurisdictions
- Verifying ultimate end-users and end-uses when transactions involve complex supply chains, intermediaries or higher-risk markets
- Determining how far organizations should go when conducting enhanced due diligence and documenting compliance efforts
- Responding when a supplier, vendor or business partner is not itself restricted but has ownership, control or other affiliations with restricted entities
- Establishing appropriate re-screening frequencies and identifying changes or risk triggers that should prompt additional review
- Assessing transaction chains involving transshipment hubs and other jurisdictions presenting elevated diversion or circumvention risks
- Strengthening certifications, contractual protections and other safeguards to mitigate unauthorized reexport, diversion and downstream misuse risks
- Developing escalation procedures and contingency plans when screening or due diligence identifies potential compliance concerns