“A U.S. automotive company’s trading with Iran might be perfectly legal under EU sanctions but still violate U.S. law,” he pointed out in a video interview with AIAG following the Export Sanctions Update he gave to attendees at the Customs Town Hall.

Husisian has extensive experience in export controls and sanctions, the Foreign Corrupt Practices Act (FCPA), corporate risk management and compliance, and issues arising from international trade. He advises clients regarding various export control issues under the Department of State’s International Traffic in Arms Regulations (ITAR) restrictions, and the Department of Commerce’s dual-use regulations (EAR), as well sanctions/embargo issues under the Office of Foreign Assets Control (OFAC) regulations. Husisian also counsels clients regarding the Foreign Corrupt Practices Act (FCPA).

“The U.S government has very concrete compliance expectations for U.S. companies, regardless of whether it’s in export controls, OFAC sanctions, anti-corruption, or anti-money laundering areas,” he said. “They exert U.S. law worldwide, and they expect companies to identify risk points, manage their risk, and put in place effective compliance policies and back them up with good internal controls and with good training.”

Husisian clarified that a good paper compliance program is not enough, and if companies haven’t adequately managed their risk, the U.S. government may come down on them “in a very harsh manner.”

His practice covers compliance, due diligence, enforcement, mergers and restructurings, and other issues relating to U.S. regulation of international conduct and the export of U.S.-origin goods, information, and technology. He advised automotive companies to perform a risk assessment if they haven’t done one in the last two years.

“Generic compliance programs are not enough,” he emphasized during the interview. “You have to take into account how you do business, identify the risks, and figure out how to allocate your compliance resources to address the risk you’ve identified.”

Many exporters are finding it difficult to navigate the constantly changing rules that govern trade in U.S.-origin goods and the dealings of U.S. companies operating and selling abroad, he said. Husisian’s presentation focused on the compliance expectations of the U.S. government in exports and international trade, including the easing of the Cuba and Iranian sanctions, the aggressive application of U.S. law abroad, and the concrete steps that companies can take to enhance their international regulatory risk management.

View full video here.

About AIAG

The Automotive Industry Action Group is a unique not-for-profit organization where OEMs, suppliers, service providers, government entities, and individuals in academia have worked collaboratively for more than 30 years to drive down costs and complexity from the supply chain. AIAG membership includes preeminent manufacturers and many of their parts suppliers and service providers. For more information, visit www.aiag.org.