OFAC, BIS and the DOJ have published a Compliance Note on ‘cracking down on third-party intermediaries used to evade Russia-related sanctions and export controls’. Notice & Press Release. The note identifies: Possible circumvention techniques, including the use of “transshipment points” and obscuring identities of Russian end-users. 13 red flags that can indicate a third-party intermediary may be engaged in efforts …
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Michael is Senior Partner at Peters & Peters Solicitors LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters &...
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