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
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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