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Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note

News & Blog

The Department of Commerce, Department of the Treasury, and Department of Justice have issued a joint compliance note warning companies on the use of third-party intermediaries and transshipment points to evade sanctions. In the note they list several red flags to a transaction including:

Use of corporate vehicles (i.e., legal entities, such as shell companies, and legal
arrangements) to obscure (i) ownership, (ii) source of funds, or (iii) countries involved,
particularly sanctioned jurisdictions;

A customer’s reluctance to share information about the end use of a product, including
reluctance to complete an end-user form;

Use of shell companies to conduct international wire transfers, often involving financial
institutions in jurisdictions distinct from company registration;

Declining customary installation, training, or maintenance of the purchased item(s);
IP addresses that do not correspond to a customer’s reported location data;

Last-minute changes to shipping instructions that appear contrary to customer history
or business practices;

Payment coming from a third-party country or business not listed on the End-User
Statement3 or other applicable end-user form;

Use of personal email accounts instead of company email addresses;

Operation of complex and/or international businesses using residential addresses or
addresses common to multiple closely-held corporate entities;

Changes to standard letters of engagement that obscure the ultimate customer;

Transactions involving a change in shipments or payments that were previously
scheduled for Russia or Belarus;

Transactions involving entities with little or no web presence; or

Routing purchases through certain transshipment points commonly used to illegally
redirect restricted items to Russia or Belarus. Such locations may include China
(including Hong Kong and Macau) and jurisdictions close to Russia, including Armenia,
Turkey, and Uzbekistan.

The complete note can be review at:

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