The final quarter of 2019 saw a burst of wide-reaching sanctions developments from China to Latvia, capping off another record year of U.S. sanctions implementation and enforcement. In the wake of rising military tensions with Iran, the U.S. imposed new secondary sanctions on the country’s construction, metals, and transport sectors. Congress finished the year by passing new Chinese sanctions in response to human rights concerns, while OFAC issued guidance to help stabilize the global shipping industry following its sanctioning of major Chinese shipping firms. Meanwhile, the U.S. imposed new sanctions on the construction of natural gas pipelines to Europe, and warned allies against purchasing Russian-made armaments. OFAC also continued efforts to squeeze Venezuela’s oil trade, and took significant action to target corruption and human rights abuses around the globe. Finally, Exxon Mobil Corp. secured a rare court victory in reversing an OFAC civil penalty for alleged Ukraine-related sanctions violations after a court determined that the agency’s regulations failed to give Exxon fair notice that its conduct was prohibited.

View full memo, Sanctions Round Up Fourth Quarter 2019.