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The headline for the second quarter is, of course, the United States’ enforcement action against Bank BNP Paribas and its breathtaking penalty of $8.9 billion, tied to the allegedly intentional evasion of the US sanctions programs for Sudan and, to a lesser extent, Iran and Cuba. This settlement capped off a series of enforcement actions by US authorities against a variety of actors stemming from violations of all sizes.
Otherwise, most of the action in the past quarter involved the increasingly tense situation in Ukraine, with the United States and Europe implementing targeted and escalated sanctions against actors in Russia and Ukraine in response to ongoing aggression by separatists in the region. As this quarter drew to a close, both the United States and European Union were reportedly threatening sector-based sanctions. With respect to other sanctions programs, the quarter was largely marked by what has come to be viewed as routine activity, with the United States continuing to make limited designations under sanctions targeting Iran’s proliferation of nuclear weapons, foreign terrorist organization operations, and international narcotics traffickers.