In a video interview conducted on April 13, 2023, SupplyChainBrain featured Ashley Craig explaining the Tri-Seal Compliance Note, a published joint advisory from the U.S. Department of Commerce, the U.S. Department of the Treasury, and the U.S. Department of Justice, cracking down on violators of U.S. sanctions and export controls targeting Russia and Belarus.
Discussing the intentions of the note, Craig explained that the U.S. agencies want exporters to beware of “bad actors” who have attempted to undermine or circumvent the sanctions through “a litany of different means,” Craig said. “This provides notice that the government is aware, and that you’d better be mindful,” he said.
The note also stressed the need for exporters to exercise “heightened caution and additional due diligence.” What it comes down to, Craig said, is that the onus is on the individual company to meet the mandate for compliance. “Willful ignorance is not going to help you.”
Craig further explained that you must know the mantra, “know your customer.” It’s vital that exporters properly vet the parties to which they’re shipping, although that becomes more difficult to do if the goods in question then pass through multiple hands. How far down the chain must the seller go? “The U.S. government would say, as deep as you need to go,” said Craig. That said, it becomes extremely difficult to trace the provenance of exported goods beyond a certain point.
“You know who your direct customer is,” he said. “If there’s reason to believe that there’s going to be a resale, you’ve got to go one step beyond and ask your customer, ‘Who are you dealing with?’”
To view the full video interview, please click here.