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U.S. sanctions authorities remained active in the first quarter of 2020, even as international focus turned toward combating the COVID-19 pandemic. OFAC and the U.S. State Department imposed secondary sanctions on firms in China and elsewhere for continued dealings with Iran. Meanwhile, the Trump Administration authorized new sanctions on Iran’s construction, mining, manufacturing, and textile sectors, and ratcheted up restrictions on the country’s largest metals manufacturers. In response to Iran’s continued uranium enrichment efforts, Europe’s JCPOA signatories triggered a dispute mechanism to try and save the nuclear agreement. Elsewhere, OFAC blacklisted two Rosneft subsidiaries in an attempt to curb Russia’s support for Venezuela’s oil trade. Finally, a Swiss technology firm’s settlement with OFAC illustrates the sanctions risks to non-U.S. companies using U.S. origin technology.
