Jonathan Poling Quoted by Compliance Week on U.S. Sanctions Approach
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Compliance Week, for its article “Compliance Remedies for New Sanctions Headaches,” quoted Akin Gump international trade partner Jonathan Poling on what it calls a more nuanced approach in the targeting of sanctions.
On the challenges of employing sanctions that target individuals, companies and specific activities within designated industries versus blanket sanctions, Poling said, “The Obama Administration is trying [a] very different approach to sanctions. In a sense, comprehensive sanctions are much easier for companies to administer, but sanctions targeting specific uses in specific industries are a compliance challenge, because now you have to get all sorts of assurances from counterparties, and you have to do greater due diligence to ensure that the transaction falls outside of the prohibited type of conduct that’s restricted.”