The U.S. Department of Justice, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), issued a Tri-Seal Compliance Note: “Obligations of Foreign-based Persons to Comply with U.S. Sanctions and Export Control Laws” today providing guidance regarding the ability of the U.S. government to hold both U.S. and non-U.S. persons and companies accountable for violations of U.S. sanctions and export control laws.
