Comment from Ian Stewart: this post is reproduced from nonproliferation.org. I would welcome the opportunity to give additional book talks, including talks which are more contemporarily focused. Please reach out.
On October 4, 2021 CNS hosted a webinar at the Monterey Institute of International Studies at Monterey, CA featuring Dr. Ian Stewart, executive director at the CNS Washington DC office. He is a specialist on issues related to export controls, sanctions, and nonproliferation.
The US Department of Commerce's Bureau of Industry and Security (BIS), the Department of the Treasury's Office of Foreign Asset Control (OFAC), and the Department of Justice have issued a joint compliance note on the use of third-party intermediaries or transshipment points to evade Russian and Belarusian-related sanctions and export controls. The note highlights the most common tactics used to evade these controls and provides guidance to companies on how to maintain an effective, risk-based sanctions and export compliance program.
The following is an excerpt from the article, available in full at the Strategic Trade Review.
