The first months of the Biden Administration signaled the new US President’s willingness to remain tough on China in the short term.  Meanwhile, the new Administration appeared to pause the US “maximum pressure” policy against Iran as it engages in multi-lateral discussions to explore options for resuming US participation in a nuclear deal.  In other developments this quarter, the US re-imposed sanctions against Myanmar in response to the unfolding military coup and announced new restrictions against Russia in response to last year’s poisoning of Alexei Navalny.  Finally, OFAC announced settlements with three companies for compliance failures, including against a US-based digital-currency service provider.

View full memo, Sanctions Round Up First Quarter 2021