Recently, 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) released a joint compliance note.
The note highlights the typical tactics used by harmful actors in maritime and other transportation industries. It also mentions recent legal actions taken to ensure compliance for suspected breaches of U.S. sanctions and export controls.
It is important to understand the rules in place when transporting, especially when doing business in high-risk areas and the below categories of cargo:
Manipulating location or identification data
Falsifying cargo and vessel documents
Voyage irregularities and use of abnormal shipping routes
Frequent registration changes
Complex ownership or management
It is also important for people and companies involved in maritime and transportation to implement compliance controls when necessary. Below is a list of compliance practices that may help identify potential regulatory evasion efforts:
Institutionalizing sanctions and export control compliance programs
Establish location monitoring best practices and contractual requirements
Know your customer
Exercise supply chain due diligence
Industry information sharing
Companies are strongly encouraged to check their risk of sanctions and exports. Operating in the maritime and transportation industries comes with a significant responsibility to adhere to U.S. laws and regulations governing the shipment of cargo. Failure to meet compliance requirements can lead to severe consequences, including penalties, potential prison time, and various enforcement actions from different agencies.
Want to learn more? Click the button below to view the full compliance note:
Companies must recognize the legal consequences of non-compliance. Penalties, enforcement actions, and imprisonment risks underscore the need for robust compliance controls and risk assessments. Staying proactive in addressing red flags ensures supply chain integrity. Our law firm is ready to provide expert guidance for companies aiming to maintain compliance.
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