ILMA Compoundings – December 2019 - 11

product to a Canadian Company (wherever located) without
adequate measures in place to prevent the secondary sanctions
infraction by Canadian Company A.
As a second illustration, consider a scenario where Canadian Company A acquires a Canadian origin product that
is comprised of 28% content made using U.S.-owned formulary technology. Imagine then that Canadian Company
A (wherever located) sells this product to prohibited Turkish
Company B, that is also located in Canada. Here, Canadian
Company A would risk U.S. secondary sanctions penalties
based on the U.S. technology content (even though the
product manufacture occurs in Canada), and the U.S.
technology owner could also be implicated for prohibited
sanctioned activity if it allowed Canadian Company A to
utilize its U.S. technology without adequate controls.
Actual commercial scenarios can be more complex
than the illustrations provided here, but the illustrations
demonstrate a few of the many ways that normal commercial conduct can breach secondary sanctions, resulting in

substantial penalties that might include both criminal and
civil charges.
CONTROLS AND VIGILANCE NEEDED
OFAC is at liberty to impose new sanctions and/or secondary sanctions with minimal advance warning. The executive
order continues in effect. Even if the risk of the underlying
reason for the issuance of the executive order (Turkey's
military aggression) completely disappears, OFAC is still
empowered to use its authority to impose primary and
secondary sanctions, virtually at will, subject only to published notice. Vigilance with regard to the U.S. sanctions
environment is always recommended. Utilizing adequate,
up-to-date controls concerning sanctions compliance and
related risks is increasingly essential.
Eggenschwiler, an ILMA consultant, is an international
trade attorney and director of global trade for the Redstone
Group, a Trinity Consultants Company. He can be reached
at 614-923-7472 or jeggenschwiler@redstonegrp.com.

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ILMA Compoundings – December 2019

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