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05/27/2019

Office of Foreign Assets Control: 2019 Changes

The year 2019 has brought many changes to the U.S. Sanctions Program and navigating these changes can be challenging for financial institutions. The Trump Presidency has been very active in driving the many changes in the U.S. Sanctions Program. For example, there have been 26 rounds of sanctions against Iran during the Trump Presidency.  Additionally, there have also been changes to the Venezuela, Russia, North Korea and Cuba sanctions programs. Further, OFAC has continued to use secondary sanctions to extend the reach of its sanctions regulations. Moreover, OFAC has taken an aggressive approach to enforcement, which was reflected in OFAC’s actions taken against entities not in compliance with applicable regulations. In this paper, we will go over the notable changes made and guidance issued thus far in 2019.

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