Shearman And Sterling

Sanctions Round Up: Second Quarter 2021

October 27, 2021

Sanctions Roundup: Third Quarter 2021

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SANCTIONS ROUNDUP: THIRD QUARTER 2021

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.

View full memo, Sanctions Roundup: Third Quarter 2021.

Authors and Contributors

Philip Urofsky

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Danforth Newcomb

Of Counsel

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Stephen Fishbein

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Brian G. Burke

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Christopher L. LaVigne

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Barnabas Reynolds

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Mark D. Lanpher

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Paula Howell Anderson

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Adam B. Schwartz

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Katherine J. Stoller

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Jacob Fields

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Cole Pritchett

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Blair Campion

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