A Tri-Seal Compliance Note (“Note”) has been released by the Department of Commerce, Department of Treasury, and Department of Justice to assist businesses in identifying warning signs and implementing appropriate compliance measures to ensure cooperation with Russian-related sanctions and export controls. One of the most common sanction evasion tactics highlighted in the Note is the use of third-party intermediaries or transshipment points, to hide the involvement of sanctioned individuals or entities on the Entity List and obscure the actual identities of Russian end-users.

The Note highlights red flags and factual examples from recent enforcement cases that could suggest a plan to evade U.S. sanctions and export controls. We provide a detailed overview of the Note in this post.