The US departments of Commerce, Treasury, and Justice have issued joint guidance on “how Russia uses third-party intermediaries and transshipment points to circumvent restrictions and obscure the true identities of Russian end users.”
The “Tri‐Seal Compliance Note: Cracking Down on Third‐Party Intermediaries Used to Evade Russia‐Related Sanctions and Export Controls” (the “Note”) highlights the efforts of the three departments over the past year to counter trade in certain products with the purp...
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