Last quarter, as the Trump Administration wound down, it continued to impose expanded sanctions against China and Iran.  New executive orders targeted Chinese app developers and banned U.S. investors from holding public securities in dozens of Chinese companies with perceived military ties.  In a last-minute effort to entrench its “maximum pressure” policy, the outgoing Administration sanctioned a host of actors in Iran’s financial and steel sectors and re-designated many Iranian targets under counterterrorism authorities, potentially making their removal politically more difficult.  Numerous other developments from last quarter included new legislative sanctions on the Nordstream 2 and Turkstream pipelines, the re-listing of Cuba as a State Sponsor of Terrorism, and continued US efforts to curb Venezuela’s oil exports.  Notably, in its first week, the Biden Administration has already signaled a new international approach, as Treasury Secretary Janet Yellen announced a general review of U.S. sanctions policy and President Biden ordered agency heads to evaluate whether U.S. sanctions are “unduly hindering responses to the COVID-19 pandemic.”

View full memo, Sanctions Round Up: Fourth Quarter 2020.