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The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual currencies. OFAC also imposed new restrictions on the export of U.S.-origin munitions and military technology to Russia, sanctioned several Chinese officials in Hong Kong for purported encroachments on the region’s autonomy, and continued targeting military leaders and their support networks in Myanmar. This quarter also saw numerous enforcement actions against U.S. companies based on activities by their non-U.S. affiliates, underlining the need for an enterprise-wide compliance approach. Finally, OFAC released the results of a nine-month audit of U.S. sanctions policy, which acknowledged the need to modernize sanctions enforcement tools and methodologies.
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