Clifford Chance

Strength In Numbers: The First "Tri-Seal Compliance Note" Amplifies Third-Party Sanctions And Export Controls Evasion Risks And The Need For Strong Compliance Programs To Manage Those Risks

March 6, 2023

On March 2, 2023, the U.S. Department of Commerce (Commerce), U.S. Department of the Treasury (Treasury), and U.S. Department of Justice (DOJ) issued their first "Tri-Seal Compliance Note" (Note). The Note, "Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls," amplifies prior warnings from the U.S. Government regarding compliance risks for companies arising from attempts by counter-parties to evade Russia-related sanctions and export controls. These U.S. compliance risks have expansive extraterritorial application for companies anywhere in the world transacting in U.S. dollars, U.S.-origin or controlled products, information and data, or U.S. persons.

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