Third-party risk management
Third-party risk management in Trade and Geopolitical Risk is no longer a back-office compliance exercise. The U.S. Department of the Treasury's Office of Foreign Assets Control, the U.S. Department of Commerce Bureau of Industry and Security, and the European Commission's Directorate-General for Trade have each issued guidance or enforcement actions in the past two years that place direct accountability on firms for the sanctions exposure and export control status of their vendors, freight partners, and intermediaries. Compliance teams are now mapping supplier contracts against OFAC's 50 Percent Rule ownership thresholds and BIS Entity List additions before those relationships touch a single transaction.
Watch
- BIS Entity List additions affecting semiconductor and dual-use goods suppliers
- OFAC 50 Percent Rule: beneficial ownership tracing requirements for indirect vendor relationships
- EU Mandatory Due Diligence Directive proposals expanding third-party supply chain obligations
- Forced labor import bans under UFLPA and their downstream vendor audit requirements
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to third-party risk management will appear here as they are published.