- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2023-03-06T20:01:00
Three U.S. agencies issued guidance to highlight common methods bad actors use to evade sanctions and export controls on Russia and how to spot their use.
The Department of Commerce’s Bureau of Industry and Security (BIS), Department of the Treasury’s Office of Foreign Assets Control (OFAC), and Department of Justice (DOJ) issued the joint compliance note Thursday regarding the use of third-party intermediaries or transshipment points to circumvent the penalties placed on Russia by the United States for waging war against Ukraine.
The note listed red flags U.S. companies should look for as possible signs of sanctions or export controls evasion by third-party intermediaries:
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The Treasury Department’s Office of Foreign Assets Control announced expanded sanctions against the Belarusian regime three years after the country’s disputed 2020 presidential election.
U.S. banking regulators combined to issue final guidance on managing the risks of third-party relationships that replaces the previous documentation each agency released individually.
New York attorney Robert Wise faces up to five years in prison after pleading guilty to making payments to maintain U.S. properties secretly owned by sanctioned Russian oligarch Viktor Vekselberg.
The U.S. Supreme Court extended the statute of limitations for businesses attempting to challenge some federal regulations, allowing regulated entities a longer timeline to appeal a decision.
The Supreme Court of the United States overturned a long-held precedent in which courts deferred to federal agencies in interpreting complex or ambiguous regulations–a decision that could make thousands of federal regulations more vulnerable to legal challenges.
Financial institutions would be required to conduct more thorough risk assessments on their anti-money laundering/countering the financing of terrorism programs under a new rule proposed by the Treasury Department’s Financial Crimes Enforcement Network.
