On Friday evening, you get a call informing you that your company’s German subsidiary may have shipped products to Iran. How do you confirm this allegation is true? Do you inform the board? Should you tell the government? You ask yourself, “What do I do next?”

When a company discovers that it may have committed a violation of economic sanctions or export control (ES/EC) laws, it needs to react swiftly and methodically. The following checklist provides guideposts for considering and conducting such investigations, with emphasis on features unique to ES/EC laws.

  • Assess the Information.

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