Foreign Adversary Ownership Rules and Supply Chain Risk
Sponsored by:
FREE Webinar
CSS Credits: 1.25
Duration:
75 minutes
Speakers:
- Colby Potter | Sayari
Moderator:
Date:
Time:
- 11:00 AM – 12:15 PM NYC
- 04:00 PM – 05:15 PM London
- 05:00 PM – 06:15 PM Amsterdam
Description:
Sanctions screening is evolving. Looking beyond listed entities is now standard practice, but newer requirements targeting foreign adversary ownership, including FOCI reviews and FEOC restrictions, have layered fresh tests on top of the OFAC 50 Percent Rule and the BIS Affiliates Rule. And these tests don’t stop at direct counterparties. They reach into supply chains, where restricted entities evade standard screening. This session maps the converging regimes, then shows how combining authoritative corporate and trade records can surface adversary-controlled networks.
After this session, attendees will be able to:
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Map the converging ownership-based regimes (FOCI, FEOC, Section 889, 1260H, and others) alongside the OFAC and BIS 50 percent thresholds they already screen against.
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Compare how each regime defines ownership and control, including tests that capture minority stakes, governance rights, and officer-level foreign ties below the 50 percent line.
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Recognize how restricted and sanctioned entities reach markets through intermediary suppliers and jurisdictions, and why counterparty-level screening misses this exposure.
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Trace adversary-controlled networks by combining corporate ownership records with trade data, extending ownership analysis two and three tiers into supply chains.
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Build a defensible record when ownership risk surfaces: provenance to primary sources, factual development under privilege, and reporting and disclosure consideration
Certificate of Attendance:
All active ACSS members will be able to download the certificate from the Learning Management System (under the achievements tab).
Event Registration
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Speakers
Colby Potter
Moderator
Ivy Llena
ACSS
Before joining ACSS, she was a program director at a non-profit organization in the Philippines, where she co-designed and co-implemented economic empowerment programs and services for survivors of human trafficking and their families. Ivy also served at the Social Policy Institute at Washington University in St. Louis, where she led and contributed to inclusive economic growth initiatives.
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