OFAC 2020 Year in Review – Part I

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Author: Morrison & Foerster
Published: February 16th
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The following client alert is courtesy of CGCC member Morrison Foerster. This resource does not, and is not intended to constitute legal advice.

In too many ways to count, 2020 was an extraordinary year.  As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) may not be the first thing on your mind. Yet, 2020 was an incredibly busy year in the sanctions world as the Trump Administration continued to rely on sanctions as perhaps its primary national security and foreign policy tool of choice.  To refresh your recollection of the year, we are summarizing the most significant U.S. sanctions developments of 2020 — including enforcement and designations statistics, programmatic changes, and major lessons gleaned from enforcement actions — in a two‑part series. In this Part One, we summarize OFAC’s major actions and programmatic developments in 2020. Part Two will summarize the year’s OFAC enforcement actions and key lessons to be learned from them.

CLICK HERE to read Part One

For any questions, kindly contact Jiang Liu, jiangliu@mofo.com