Global Policy Implementation



Service Overview

For organizations operating across global jurisdictions, sanctions compliance has become increasingly complex. OFAC’s broad definition of U.S. persons and property, along with the recent imposition of “secondary sanctions” that target non-U.S. persons, means that all businesses, American or otherwise, must ensure that all transactions with a U.S. nexus comply with OFAC sanctions. To make matters even more complicated, companies must additionally contend with the proliferation and increased involvement of other sanctions regimes, including the UN, EU, UKHMT, and HKMA, as well as local regulatory agencies.

Blackstone has experience implementing sanctions programs in over 18 countries and we know the ins and outs of working around the constraints of operating on a global scale. We understand the challenges and obstacles created by data privacy, conflict of law and different regulatory expectations, but we also know that most businesses that operate internationally don’t have the resources or manpower to commit to a full-fledged compliance department at every location. Blackstone will help you work around these constraints to build up your program, protect your interests, and stay on your regulator’s good side without interfering with business and profits, nor local legal issues and politics.


 Key Features:

23 by 18 checkmarkAssist in design and issuance of group or global policies

23 by 18 checkmarkConduct gap analysis between group-level and local policies to identify areas of remediation

23 by 18 checkmarkDevelop and execute teams to monitor and ensure group policy at all locations

23 by 18 checkmarkIdentify methodology to manage exemptions from policy based on local laws and capabilities