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ARTICLE · 19 MARCH 2024

Commerce, Treasury, DOJ Publish Tri-Seal Sanctions And Export Control Compliance Note

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On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note ...

United StatesInternational Law
Nicole Sayegh Succar
Nicole Sayegh Succar
Kelsey Clinton
Kelsey Clinton
Chandler Leonard
Chandler Leonard
Andrew Schlegel
Andrew Schlegel

On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled "Obligations of foreign-based persons to comply with U.S. sanctions and export control laws" (the "Note"). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and export controls, and that foreign individuals and companies face legal exposure should they engage with sanctioned persons/jurisdictions or deal with items subject to the Export Administration Regulations (EAR). In addition to highlighting specific enforcement examples in which non-U.S. persons were held accountable for violations of U.S. sanctions and export control laws, the Note provides an overview of compliance considerations and measures for non-U.S. persons to help mitigate these risks.

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