By Ama Adams, Brendan Hanifin and Emerson Siegle (December 16, 2021, 2:25 PM EST) — Following the 2020 election, the Biden administration announced a top-to-bottom review of U.S. sanctions policy.
While the announcement signaled a potential pause in the steady expansion of the sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control under the previous administration, the first year of the Biden presidency has been marked by significant changes to U.S. sanctions regulations and a consistent enforcement approach by OFAC, largely driven by geopolitical developments.
Regulatory Developments — and Nondevelopments
Throughout 2021, OFAC formalized — and, in some respects, expanded — Trump-era sanctions targeting China.
In January, OFAC implemented…