Workshop B — Your Third Party and Supply Chain Due Diligence and Screening Action Plan: A Step-by-Step Guide to Incorporating New Export/Re-Export Controls, Economic Sanctions, Forced Labour and More Requirements

Jan 28, 2025 1:30 pm – 05:00 PM

Phillip Cedoz
Vice President of Trade
Comtech Telecommunications Corp.

Penny Moulton
Director Customs and Trade Compliance Canada
UPS SCS, Inc.

From economic sanctions to forced labour laws on both sides of the border and changing export controls, this session will delve into how to vet prospective business and supply chain partners, mitigating supply chain risks and how to build your contingency plan in these uncertain times.

Topics will include:

  • Economic sanctions and export controls due diligence for third parties:
    • Special considerations with regard to Russia and China-related risks
    • Steering your company to collect the best data for complying with sanctions regulations
    • Managing jurisdictional differences: Using a more nuanced approach on what, when, and how to report issues to auditors, including whether such disclosures may prematurely trigger the auditors’ own reporting obligations
    • Addressing sanctions investigations with customers: Striking a careful balance between compliance with legal obligations, cooperating with authorities, and protecting customer confidentiality
  • Due diligence for third parties affected by Canadian and U.S. forced labour laws:
    • Determining what is considered forced labour and examining the threshold
    • Canadian compliance corollaries to UK & Australian forced labour laws
    • How to investigate who is in the supply chain and what is considered appropriate evidence
      • Screening and risk mitigation:
        • The pitfalls to avoid when developing your shortlist of suppliers for screening
        • New, emerging supply chain risk factors-and how to evolve your export and reexport compliance practices in response
  • Conducting third-party audits:
    • Revisiting the lengths and limits of questionnaires
    • Audit rights: Including provisions that allow for audits to verify compliance
    • Dealing with third parties who are uncooperative
    • Training requirements: Mandate that third parties receive training on export control regulations-and determining if and when to provide any training