Publication of Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls

Today, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the U.S. Department of Justice (DOJ), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), issued a Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls to alert the international community, the private sector, and the public to attempts by malign actors to continue to try to evade sanctions and export controls to support Russia’s military-industrial complex in support of Russia’s illegal and unprovoked war against Ukraine.  The Compliance Note details how Russia uses third-party intermediaries and transshipment points to circumvent restrictions and obscure the true identities of Russian end users.  The Compliance Note provides common red flags that can indicate a third-party intermediary may be engaged in efforts to evade sanctions or export controls.