Pharmaceutical Supplier Office of Foreign Assets Control Compliance

A pharmaceutical supplier requested assistance in the evaluation of their Office of Foreign Assets Control compliance out of concern that some of their procurement activity may entail importing from countries that may have restrictions over certain categories of product. The scope of the project was expanded to include not only export controls and sanctions, but also compliance with the U.S. Foreign Corrupt Practices Act. Further, it was recommended that the project be overseen by counsel since such a review could reveal instances of non-compliance that could give rise to liability. Ultimately, a project team reviewed policies and procedures, procurement and importation operations, government licensing and other substantive interactions with foreign government officials and delivered a report which gave the client a much clearer picture of their OFAC, sanctions, export controls and FCPA risk and their current risk mitigation capabilities. This led to the development of an action plan to assist the company to utilize internal resources to strengthen its export controls, sanctions and FCPA compliance programs.