International and Export Controls & Economic Sanctions lawyers Timothy O'Toole and Abigail Cotterill* authored the "U.S. Export Controls and Sanctions Risks in the Manufacturing Supply Chain," chapter in The Export Compliance Manager's Handbook, published by WorldECR. This handbook is designed to act as a primer on key areas of export control compliance practice and serve as a guide to navigating typical challenges in the space. O'Toole and Cotterill's chapter addresses the specific risks that can arise when foreign suppliers, foreign nationals in the United States, Specially-Designated Nationals (SDNs), other blacklisted parties, and controlled U.S.-origin items unintentionally or unknowingly enter a company's supply chain. "Many exporters and compliance professionals focus intensely on customer and diversion risks, while providing far less attention to what happens before the ultimate export of a product occurs, neglecting risks from their own supply chains," the authors wrote. "You can't be all knowing and all seeing, but you can know where to look and do some reasonable due diligence so that you and your clients can spot and address these risks."

*Former Miller & Chevalier attorney