Case: Non-compliance at Fokker Services
AbstractFrom late 2005 through to late 2010, Fokker Services BV (FSBV) failed to comply with the economic sanctions the United States (US) Government had established against Iran and Sudan. By scanning the case, violations by FSBV came to light in a structured way, laying bare how FSBV operated to evade export control, breaching sanctions regimes and export control laws. Next, analysis stipulated that the cause and conditions of the violation of the export control regulations were mainly rooted in the tone at the top, the role of (intermediary) management and the absence of a Compliance Program. Subsequently, a short-term and a long-term response were formulated addressing the tone at the top, the development of an Internal Compliance Program, and the application of soft controls to promote an ethical culture.