On December 5, 2023 and December 6, 2023, respectively, the US and UK Governments announced new sanctions and export control measures targeting Russia focused on persons and entities in third countries supporting Russia’s military and defense industrial base and its war in Ukraine. US Sanctions and Export Control Updates The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions targeting a network led by Belgium-based individual, Hans De Geetere, as well…
On July 26, 2023, the US Departments of Treasury, Commerce, and Justice published a Tri-Seal Compliance Note on the voluntary self-disclosure (“VSD”) of potential violations of US sanctions, export controls, and other national security laws (the “VSD Note”). This publication is the second Tri-Seal Compliance Note issued by the agencies and continues the enforcement focus on the sanctions and export control measures targeting Russia in particular and national security concerns more generally. The first Tri-Seal…
On March 2, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”), the US Department of Justice (“DOJ”), and the US Treasury Department’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 (“Compliance Note”) warning the public of efforts to evade Russia-related sanctions and export controls via use of third-party intermediaries and transshipment points. To aid the…
On 22 February 2023, the US Department of Justice (DOJ) announced a new voluntary self-disclosure policy for corporate criminal enforcement in all United States Attorneys’ Offices (USAOs) around the country. USAOs are often the front-line of DOJs enforcement efforts, prosecuting federal criminal cases in each of the 94 federal judicial districts across the country. This includes the prosecution of many criminal violations of US sanctions and export controls. Even when these cases are brought by one…