WHERE is it written?
Every European company, regardless of its size and the sector in which it operates, is obliged by law to provide for and monitor the sanctions lists. In the European Union (EU) it is sanctioned by the EU regulations on sanctions and embargoes. Violations of the prohibition rules are punished with imprisonment from 1 to 10 years (National Foreign Trade Law).
The additional obligation to comply with the US lists is established by the "US-Export Administration Regulations" or the "US-Person" requirement. The provisions concerning "Secondary Sanctions" obligate every company in the world to execute Sanction-Screening of US lists. Violations of US prohibition rules are punished with heavy prison terms and with inclusion on US lists. Inclusion in the lists involves the prohibition of purchasing US assets from American companies and in the United States and of selling goods to American companies and in the States. There are many European companies that comply with US listings and deny the supply of goods to companies registered in them. With the entry into the United States there is the risk of arrest and condemnation of a heavy prison sentence (in an American prison).
Failure to provide or execute a Sanction-Screening is imputed as an imprudent and intentional "fault of organization". If the failure leads to carrying out a prohibited commercial activity with a person, company or organization falling within the sanctions lists, it is also imputed as an intentional offense by the management body or the administrative councils / steering committees.
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