U.S. Regulators Emphasize Pursuit of Enforcement Actions Against Non-U.S. Persons and Entities

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May 13, 2024

U.S. Regulators Emphasize Pursuit of Enforcement Actions Against Non-U.S. Persons and Entities

Business Crimes Bulletin

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On March 6, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of Justice (DOJ) collectively issued a Tri-Seal Compliance Note emphasizing that non-U.S. persons and entities must comply with U.S. sanctions and export controls law, and cautioning that they could be subject to civil and criminal liability for a failure to do so. See, U.S. Dep’t of Com., U.S. Dep’t of the Treasury & U.S. Dep’t of Justice, Tri-Seal Compliance Note: Obligations of Foreign-based Persons to Comply with US Sanctions and Export Control Laws (Mar. 6, 2024) (Compliance Note). Tri-Seal Compliance Notes are not frequently issued, and practitioners should take note when all three sanctions regulators speak on an issue with a single voice.

To continue reading Harry Sandick and Sarah Hardtke's article in Business Crimes Bulletin, please click here.

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