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With the war in Ukraine raging on, the U.S. continued to escalate its sanctions response against Russia. The U.S. announced extensive trade and investment bans that prohibit U.S. persons from making any “new investment” in the Russian Federation, and imposed additional blocking sanctions on Russia’s largest banks and Russian elites. With the future of a revived JCPOA still in doubt, the U.S. resumed sanctions against Iran’s energy sector, taking aim at sanctions evasion networks tied to its state-owned oil company. Elsewhere, OFAC announced a host of measures targeting North Korea, including virtual currency mixers and North Korea’s WMD proliferation activities. Meanwhile, multiple entities settled allegations that they caused U.S. financial institutions to process transactions involving designated persons and prohibited jurisdictions. The sanctions activity this quarter took place amid a backdrop of notable pronouncements from the Biden Administration, including a commitment that sanctions enforcement would take on a “new level of intensity” going forward.