Knowing Your Customer’s Customer? Sanctions and Tri-Seal Guidance Heighten Expectations on Companies

Companies face shifting and increasingly exacting regulatory expectations as authorities address risk areas related to national security, including sanctions. Since a 2022 statement by Deputy Attorney General Lisa Monaco stressing the importance of sanctions in corporate compliance by dubbing them “the new FCPA,” agencies have issued new guidance. Corporations must accord more vigilance to attempted evasions of sanctions and export controls. Their eyes are expected to be cast further than has customarily been the case – not only to their own and immediate partners’ activities, but to those of their customers’ customers. This article distills insights from Perkins Coie lawyers regarding the Tri-Seal Guidance, including review of certain provisions, sectors of interest, the national security focus, enforcement predictions and compliance steps. See “Measures Against Russia Pose Serious Compliance Challenges” (Sep. 27, 2023).

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