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OFAC, Commerce, and DOJ Emphasize Pursuit Of Enforcement Actions Against Non-U.S. Persons and Entities

The guidance mirrors the recent, broader impulse among U.S. prosecutors and regulatory agencies to extend application of U.S. law to foreign persons and entities, even when those persons and entities have only threadbare connections to the U.S.

11 minute read May 01, 2024 at 12:13 AM
By
Harry Sandick and Sarah Hardtke
OFAC, Commerce, and DOJ Emphasize Pursuit Of Enforcement Actions Against Non-U.S. Persons and Entities

On March 6, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS), and the U.S. Department of Justice (DOJ) collectively issued a Tri-Seal Compliance Note emphasizing that non-U.S. persons and entities must comply with U.S. sanctions and export controls law, and cautioning that they could be subject to civil and criminal liability for a failure to do so.

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