Sanctions Round Up: 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.

Please see full Newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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