On 19 August, an article from Thompson Hine LLP looked at the FAQ addressing potential red flags for diversion concerns. One asks if there any special red flags that should be considered with regard to parties (e.g. integrated circuit designers) on the Entity List. Others ask about commodities potentially diverted to restricted Russian or Belarussian companies. FAQ offer examples of potential red flags of attempts to evade Russia/Belarus sanctions by “illicit actors” who will engage “complicit shippers (or customs brokers)” to obscure a shipment to evade US export controls. BIS has identified several countries as possible transhipment points in efforts to evade these sanctions.
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