Despite the U.S. Department of Treasury being on track to bring the lowest amount of sanctions cases and penalties in 15 years, the numbers are expected to revert back to normal levels over time according to Morrison & Foerster partner John E. Smith in the Bloomberg Businessweek article “The Trump Administration Loves Issuing Sanctions, Not Enforcing Them.”
“It would be a mistake to assume that OFAC has become less aggressive with respect to enforcement of economic sanctions,” he said. “That is particularly true in this administration, which has indicated publicly and vigorously that it intends to enforce the sanctions to the maximum extent possible.”