U.S. authorities list red flags for sanction evasion by third parties

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: