FOURTH QUARTER 2019 -

- Congress closes the year by passing new sanctions against China over human rights concerns, while OFAC clarifies the scope of recent actions against Chinese shipping companies.

- In the wake of rising military tensions, the U.S. takes new aim at Iran’s construction, metals, and transport sectors, while continuing to target the country’s oil trading partners.

- Exxon scores a rare court victory against OFAC, overturning civil penalty for alleged Ukraine-related sanctions violations.

- DOJ issues revised guidance to incentivize voluntary selfdisclosures of sanctions and export-control violations.

- U.S. continues efforts to disrupt Venezuelan oil trade, while extending waivers for major U.S. companies.

- OFAC secures record number of enforcement actions, highlighting importance of screening controls and interorganization communication channels.