S&C Financial Services Lawyers Author GIR Article on Trends in Economic SanctionsSeptember 5, 2019
S&C financial services lawyers Elizabeth Davy, Jamie Earl, Eric Kadel, Jr. and Adam Szubin recently authored an article for Global Investigations Review exploring recent trends in economic sanctions programs and enforcement actions. The article, titled “Developments in Economic Sanctions, Enforcement and Investigations,” examines recent major developments in U.S. sanctions programs and then turns to enforcement actions and guidance of the U.S. Department of the Treasury’s Office of Foreign Assets Control. From these, the authors draw lessons that can be expected to apply going forward.
The article highlights increasing sanctions pressure on Iran, Venezuela, Cuba, Russia and North Korea, and observes that OFAC enforcement actions have “increased significantly” over the 12 months covered by the article, as compared to the preceding year. It also discusses OFAC’s May 2019 compliance guidelines for organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons. This OFAC Framework was released on the heels of parallel guidance from the Department of Justice. “In light of the broader trend towards more vigorous sanctions enforcement, both US and non-US entities should be aware of OFAC’s Framework and DOJ’s Guidance and their emphasis on companies maintaining robust sanctions compliance programmes,” the authors conclude.
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