Compared to prior years, this first half of 2021 has seen a drop in the number of published enforcement actions by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). The reduction is likely attributed to the new U.S. administration’s desire to realign and refocus its sanctions programs. The remainder of 2021, and perhaps through the current administration’s term, is likely to see an increase in published enforcement actions. Notwithstanding, there are still some notable enforcement actions this year, including the first-ever resolution pursuant to the U.S. Department of Justice’s (DOJ) Export Control and Sanctions Enforcement Policy for Business Organizations.
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