Tagged: joint compliance note

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of the coming enforcement storm and aggressive push against companies and individuals; and on the other hand, they provide significant compliance guidance.  Over the last five years, DOJ, OFAC...