Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note

Date issued: Mar. 02 2023

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TURBOFAC Commentary (178 words)

Notes:

1) While this is the first document given the title "Tri-Seal Compliance Note," it is not easy to distinguish from the standard multi-agency "Advisory". See e.g. Advisory on the Cyber Threat Posed by North Korea and Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors, and Related Communities.

As is typical of such advisories, the document does not break new ground as it relates to the scope and operation of OFAC-administered sanctions laws, but it does explain evasion typologies and otherwise have implications for diligence expectations in a way that would, in a hypothetical enforcement proceeding, likely have implications for that which an alleged violator "knew of" or had a "reason to know" of (see generally General Note on the Terms "Knowingly," "Should Have Known" And "Reason to Know" In the Primary Sanctions,...