CBRE is an international company and is governed by international trade controls both in the U.S. as well as trade controls prescribed by laws within local countries. Penalties for violating the trade control regulations of the U.S. and other countries can be severe. We have adopted policy guidance that identifies countries which are subject to different levels of special restrictions and requirements and/or compliance risks under U.S. international trade regulations. In addition, the regulations of certain countries include a list of individuals and entities with which we cannot do business because the U.S. Government has identified them as being involved in terrorism, money-laundering or other criminal activity. Clients may approach CBRE to inquire about CBRE services in these countries from time to time. We must not trade with prohibited countries, individuals or entities. If you have any questions regarding export control regulations, please contact the Legal or Compliance Departments immediately.

Learn More About:
Export Controls Check your knowledge

For decades, the United States has placed trade sanctions against the nation of Cuba. This includes prohibitions of the imports of goods and services to US companies. Quinn wins a massive global asset management contract to support a multinational company. While the contract originates in the US, part of the agreement includes support to properties in Japan. Takashi, Quinn's team member in Tokyo, would like to hire a Cuban vendor as part of the contract support in Japan. The Cuban vendor can provide a quality product for a cheaper price than any of their competitors. The country of Japan has no such embargo against Cuba.

Can Takashi hire the vendor since he is not in the United States?

Answer
Answer

While there are exceptions, Takashi should not hire the Cuban vendor. As a general rule, since CBRE is a company originally licensed in the United States, we follow the trade rules set forth in the US regardless of the location. Please note that this particular area of regulation can be difficult to navigate, and for further information, contact your legal or compliance office.

Incorrect Selection

Please re-examine the situation presented carefully and choose again.

 
Policy Guidance
×
A
Access to Employee Records Anti-Corruption Policy
B
Business Records Retention and Destruction
C
Communications and Fair Disclosure Policy Confidentiality / Non-disclosure Conflicts Identification and Management Policy for Government Contracts Conflicts of Interest
D
Drug-Free Workplace
E
E-Marketing Policy Electronic Communication Electronic Communications & Acceptable use of Technology: Social Media Employee Assistance Program Employment of Relatives Equal Employment Opportunity
G
Gifts and Entertainment
H
Harassment-Free Workplace
I
Inappropriate Entertainment Information Asset Protection Internal Communications Investigations of Legal and Ethical Misconduct
M
Managing Conflicts of Interests - Information Barriers Media Relations
N
Non-Retaliation
O
OFAC Compliance Open Bidding Outside Employment
P
Personal Ownership of Real Estate Political Contributions Public Relations
R
Report of Injuries/Accidents Restrictions on Marketing by Fax
S
Safe Workplace Policy Securities Compliance Smoke-Free Workplace Social Media Solicitation and Distribution Standards of Conduct
T
Timekeeping
U
Use of CB Richard Ellis Name or Identity Use of Company Property
V
Violence in the Workplace