On March 2, 2023, the United States Department of Commerce’s Bureau of Industry and Security (BIS), the United States Department of Justice (DOJ), and the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a “Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls.” The Compliance Note alerts 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.
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