U.S. compliance note on Russia-related sanctions evasion and export controls
Cracking down on third-party intermediaries used to evade Russia-related sanctions and export controls
Cracking down on third-party intermediaries used to evade Russia-related sanctions
The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce, the U.S. Department of Justice (DOJ), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today issued a “tri-seal” compliance note [PDF 388 KB] on cracking down on third-party intermediaries used to evade Russia-related sanctions and export controls.
Today’s OFAC release explains that the compliance note:
- Alerts the international community, the private sector, and the public to attempts by malign actors to continue to try to evade sanctions and export controls to support Russia’s military-industrial complex in support of Russia’s war against Ukraine
- Details how Russia uses third-party intermediaries and transshipment points to circumvent restrictions and obscure the true identities of Russian end users.
- Provides common red flags that can indicate a third-party intermediary may be engaged in efforts to evade sanctions or export controls
For more information, contact a professional with KPMG Trade & Customs services:
Doug Zuvich |
John L. McLoughlin |
Andy Siciliano |
Steve Brotherton |
Luis (Lou) Abad |
Irina Vaysfeld |
Amie Ahanchian |
Christopher Young |
Gisele Belotto |
George Zaharatos |
Andy Doornaert |
Jessica Libby Principal E: jlibby@kpmg.com |
John Anderson Managing Director E: johneanderson@kpmg.com |
Jenna Leigh Glass Managing Director E: jennaleighglass@kpmg.com |
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.