Five-agency compliance note on best practices for international cargo

The Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), Department of State’s Directorate of Defense Trade Controls (DDTC), and Department of the Treasury’s Office of Foreign Assets Control (OFAC) have issued a quint seal (five agency) joint compliance note highlighting common tactics deployed by malign actors in the maritime and other transportation industries, as well as recent criminal and civil enforcement actions taken in response to alleged violations of U.S. sanctions and export controls. The note also describes steps that the maritime and other transportation industries can take to ensure compliance with U.S. sanctions and export controls.

The compliance note includes —

• a list of potential indicators of efforts to evade sanctions and export controls in the maritime and other transportation industries
• a non-exhaustive list of compliance practices that may assist in identifying potential regulatory evasion efforts
• examples of cooperative criminal and civil enforcement efforts taken to combat the illicit shipment of cargo