SECOND QUARTER 2019 –

- US extends sanctions to encompass Iranian metals industries and other targets; Iran announces breach of nuclear accord after EU is unable to offset economic impact of renewed US sanctions.

- Turkey’s imminent purchase of Russian defense system provides first test of Trump Administration’s resolve to enforce CAATSA sanctions.

- Newly published “Framework for OFAC Compliance Commitments” reveals agency’s expectations and best practices for corporate controls.

- OFAC updates reporting requirements and announces change in approach to penalty assessments.

- On pace for a record number of enforcement actions, OFAC announces a spate of actions against travel companies for Cuba violations.