Communicating Sanctions and Business Restrictions to China Businesses, Clients and Counterparties: Why You Should Use a Customer Assurance of Compliance

Guidette Laracuente
Head-Advisory -Legal and Compliance Department
Bank of China

Alice Rojas
Director, Deputy OFAC Officer
Societe Generale Corporate and Investment Banking – SGCIB

Paul Marquardt
Partner
Davis Polk & Wardwell LLP
- Financial services KYC best practices
- With a sale to distributor or reseller, ask for assurance that they will not sell to prohibited end user
- Use certification, contract terms and conditions
- Engagement with Chinese business partners (suppliers/vendors and customers)
- Put company on notices that compliance is expected