On 2 March, OFAC, the DoJ and the Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint Compliance Notes 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 war against Ukraine. It details how Russia uses third-party intermediaries and transshipment points to circumvent restrictions and obscure the true identities of Russian end users. It also provides common red flags that can indicate a third-party intermediary may be engaged in efforts to evade sanctions or export controls.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20230302_33
https://home.treasury.gov/system/files/126/20230302_compliance_note.pdf
https://www.buymeacoffee.com/KoIvM842y
raytodd.blog 