2019 Sanctions Pulse: Three Key Trends in Regulatory Behavior

2019 was yet another busy year in the area of international sanctions. We analyzed sanctions data in order to ascertain what it can tell us about priorities in foreign policy. We found that:

  • Sanctions volatility reached a peak in 2019, primarily driven by increases in updates to OFAC sanctions.
  • OFAC both intensified its use of pre-existing sanctions regimes in 2019 and also diversified, adding numerous new regimes. This activity reflects the aggressive use of sanctions by the U.S. political leadership to achieve multi-faceted foreign policy objectives.
  • EU and others have not followed suit, with increasing divergence in list size and priorities between OFAC and other major global regulators in sanctions.
  • The rising importance of thematic sanctions at OFAC and elsewhere contradicts the narrative of sanctions as a tool to aggravate adversary nations, and indicates a shift from inter-national politics to global politics.

To address the expanding scope of sanctions requirements, while tempering compliance costs and avoiding penalties, sanctions compliance practitioners need fast access to accurate data and sophisticated screening technology from a trusted source.

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