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Trade Lawyers Say OFAC Sanctions Enforcements Becoming More Frequent, Aggressive

International Trade Today’s Export Compliance Daily

07 Mar 2019
Reprinted with permission.

Morrison & Foerster partner John E. Smith discusses the increasingly aggressive nature and number of U.S. enforcement actions taken on sanctions violations during the last few months in International Trade Today’s Export Compliance Daily article entitled “Trade Lawyers Say OFAC Sanctions Enforcements Becoming More Frequent, Aggressive.”

Smith said there is one significant change between sanctions being enforced under the Trump administration and those enforced by past administrations: their intensity. “What seems to be different is that everything is maximum sanctions pressure,” Smith said. “You’ve got a U.S. administration led by a president who likes to talk tough, act tough and be aggressive toward friend and foe alike in pursuit of U.S. national secu­rity. Combining the uncertainty and grave conditions that exist in the world with the aggressive administration means you have more aggressive enforcements.”  Smith further indicated that the trend will likely continue. “I expect that sanctions themselves will increase, and enforcement of sanctions will increase too.”

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