Outside Publication
Fracht FWO Settlement: A Primer on “Red Flags” Due Diligence First Principles, Export Compliance Manager
September 2025Partners Michael Huneke and Katelyn Hilferty co-authored an article for Export Compliance Manager analyzing the recent settlement between freight forwarder Fracht FWO and the US Department of Treasury’s Office of Foreign Assets Control and what it says about first principles of third-party due diligence.
The authors provide a background on the settlement and discuss why awareness and intent matter under US economic sanctions, how to identify and mitigate “red flags,” the parallels to other probability-based national security regimes, and how companies can mitigate and manage risk in the wake of this settlement.
Read the full Export Compliance Manager article >>
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