Compliance training and certification
Compliance training and certification requirements in Trade and Geopolitical Risk are tightening, driven by enforcement postures at the U.S. Department of the Treasury's Office of Foreign Assets Control, the U.S. Bureau of Industry and Security, and the European Commission's Directorate-General for Trade. OFAC's 2023 enforcement guidelines explicitly treat inadequate training programs as an aggravating factor in penalty determinations, which means certification gaps now carry direct financial exposure. Compliance teams are auditing training records and updating curriculum to reflect expanded controls on dual-use goods, sanctions evasion typologies, and third-party due diligence obligations.
Watch
- OFAC aggravating factor guidance: does your training cadence meet documented expectations?
- BIS Export Administration Regulations Part 732 training obligations for deemed-export scenarios
- EU Dual-Use Regulation 2021/821 third-country re-export controls entering staff certification scope
- G7 Russia sanctions coalition issuing aligned compliance program expectations across jurisdictions
Recent material activity in Trade & Geopolitical Risk
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