DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls
As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the Departments of Commerce and Treasury issued a Joint Compliance Note (“JCN”)on the importance of compliance with the Russia Sanctions and Export Control requirement, which provides important descriptions of red flags and tactics...