The recent U.S fine imposed on a French company pursuant to the Anti-Terrorism Act, 18 USC §2339 B et seq., for its payments to a terrorist organization that controlled the area where its cement factory was located in order to keep it operating, is a warning to all companies engaged in international trade. Like our government’s enforcement of the Foreign Corrupt Practices Act, 15 USC Ch. 2B §78a et seq., barring paying bribes to foreign governments or agents, the U.S. Justice Department will pursue payments made to designated terrorist organizations. Not only should you ensure your employees know and comply with these laws in international transactions, but your agent, contractor and associate agreements should represent that they do too.
Should you have any questions or problems in this regard, please contact us.
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