Russia remained at the forefront this quarter, as the Trump Administration imposed new measures and markets reacted to the threat of additional, “crushing” sanctions from Congress on Russian sovereign debt. Meanwhile, EU states continued to consider strategies to salvage the JCPOA as the US began the first phase of its Iran sanctions snap-back. OFAC resumed sanctions pressure against North Korea, focusing on Russian and Chinese targets in particular. The quarter ended with the announcement of a $5.2 million settlement in the Trump Administration’s first enforcement action against a financial institution.
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