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This quarter, the Trump Administration continued its “maximum pressure” campaign against Iran, extending sanctions to its metals industries and senior officials as prospects of an EU alternative payment system all but collapsed. OFAC also maintained focus on Venezuela, disrupting the country’s oil revenues and its ties to Cuba. Meanwhile, OFAC published new guidance for building an effective sanctions compliance program and revised regulations governing reporting requirements. On track for a record number of enforcement actions, OFAC announced multiple resolutions, including settlements with three U.S. entities for arranging Cuba-related travel services. Finally, Turkey’s scheduled purchase of a Russia-developed defense system will test the Trump Administration’s resolve in imposing mandatory CAATSA sanctions.