A Midyear Review Of US Economic Sanctions Efforts

By Michael Casey and Brendan Hanifin (June 29, 2017, 12:02 PM EDT) -- The first six months of 2017 have been among the most active periods for U.S. economic sanctions in recent memory. Since taking office, President Donald Trump has implemented new sanctions targeting Iran and announced a policy directive that will result in tighter sanctions on Cuba. His administration also is undertaking an interagency review of the landmark Joint Comprehensive Plan of Action ("JCPOA"), while Congress is contemplating imposing its own new sanctions on Russia, Iran and North Korea. The notable sanctions developments have not been limited to policy changes. Earlier this year, the Office of Foreign Assets Control resolved the largest sanctions enforcement action ever brought against a nonfinancial institution, and the agency has taken a number of aggressive positions in other recent enforcement matters....

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