STEPTOE: OUTSIDE COUNSEL
In a recently published “Tri-Seal Compliance Note,”1 the US Commerce, Justice, and Treasury departments highlighted the obligations of non-US persons to comply with US sanctions and export controls. While the expansive reach of US export controls has long been established (in the words of the Compliance Note, “the law follows the goods” in the realm of US export control law), US sanctions enforcement against non-US companies is of more recent vintage – particul...
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