The Department of Commerce, Department of the Treasury, and Department of Justice have published a Tri-Seal Compliance Note on the obligations of foreign-based persons to comply with U.S. sanctions and export control laws.

The notice reminds companies outside of the U.S. of their requirements surrounding U.S. sanctions and export control laws to mitigate risks of non-compliance, providing information on:

  • Applicability of U.S. sanctions and export control laws to foreign-based persons;
  • OFAC enforcement actions against foreign persons;
  • BIS enforcement actions against foreign companies or involving foreign-produced items;
  • Criminal enforcement of U.S. sanctions and export control laws against foreign persons and entities; and
  • Compliance considerations for foreign-based persons.

Firms should review the notice and take any appropriate action to ensure compliance with sanctions and export control requirements.

https://www.justice.gov/opa/media/1341411/dl?inline

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