Clifford Chance

Ensuring Your Compliance Is Ship Shape

December 12, 2023

U.S. Department of Commerce, Department of the Treasury, Department of Justice, Department of State, and Department of Homeland Security issue first Quint-Seal Compliance Note

On December 11, 2023, the U.S. Department of Commerce, Department of the Treasury, Department of Justice, Department of State, and Department of Homeland Security (collectively, "U.S. Authorities") issued a Quint-Seal Compliance Note ("Compliance Note") directed at a broad range of participants in "maritime and other transportation industries – including transportation companies, maintenance companies, insurance providers, other financial institutions, and other entities involved in funding or facilitating the transport of cargo."  The U.S. Authorities, once again warning of the risks of sanctions and export controls evasion attempts, strongly advise such entities to ensure that their compliance frameworks are designed to adequately identify and to manage these new risks and advise that they should "know your cargo."    The last such guidance involving the maritime sector came in 2020 from U.S. Treasury Department Office of Foreign Assets Control (OFAC), the U.S. State Department and the U.S. Coast Guard (which we wrote about here).

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