In 2023, record enforcement and continued escalation of sanctions targeting Russia commanded US headlines.
Litigation & enforcement partners Ama Adams and Brendan Hanifin, and counsel Emerson Siegle co-authored an article for Bloomberg Law providing an overview of the US Department of the Treasury's Office of Foreign Assets Control’s (OFAC) major regulatory actions in 2023, and takeaways from OFAC's record year in enforcement.
The authors noted, “To date, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) has collected over $1.5 billion in penalties, the largest haul ever recorded in a calendar year.”
“By every metric, 2023 exceeded expectations in terms of US sanctions regulatory developments and enforcement activity,” the authors said. “It has become cliché to say that ‘next year promises to be even more active,’ but against the current geopolitical backdrop—land wars in Europe and the Middle East, plus the geopolitical tensions with China—the cliché will likely prove to be true.”
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