Calder & Vance International Sanctions & Compliance Counsel

Glossary

Wind-down periods

When a measure takes effect, authorities often allow a defined period to exit existing dealings in an orderly way. Using that window — and documenting it — protects value and reduces enforcement risk.

A worked example and links to the primary regulators are added in Phase 2. For how this applies to a specific matter, a fixed-fee written position is the proportionate step.

Related terms

SDN vs sectoral sanctions The OFAC 50% Rule Ownership vs control (EU) EAR99 and ECCN

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