Foley & Lardner LLP partner Christopher Swift is quoted in the second part of the Anti-Corruption article series on “New Russia Restrictions: International Cooperation and Risk Mitigation,” offering insight on international cooperation on the restrictions and the steps businesses can take to ensure compliance.
Swift said the international cooperation in measures targeting Russia over the past two years has been “truly remarkable,” highlighting that it spans many partners in the G7, NATO, and beyond.”
“The U.S. is not just harmonizing its approach with its West European and North American allies, but really putting its thumb on the scale to try to cut off the Russian war machine from the global economy,” Swift added.
“Policies, procedures, and personnel are the three pillars of compliance,” Swift explained, emphasizing the importance to compliance of risk assessment, eliminating risk where possible, and mitigating risk where it is not. “You have to understand what are your products and services, where is the company doing business, and how is it doing that business – directly or indirectly.”
“It is a strict liability standard. If a thing winds up where it was not supposed to, you were either involved, negligent, or negligent in managing third-party risks,” Swift added.
