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ARTICLE · 09 FEBRUARY 2022

OFAC Year In Review 2021 – Part 1

Morrison Foerster
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2021 was a year of transition in the United States and for the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). OFAC's year, while busy

GlobalInternational Law

2021 was a year of transition in the United States and for the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). OFAC's year, while busy, was far different from 2020, as the Biden Administration's political team at the Treasury took office, conducted a sweeping sanctions review, and began implementing the Administration's sanctions policy priorities. Although the Biden Administration demonstrated its intent to remain tough on China and Russia, it slowed the expansion of sanctions on Iran and Venezuela, emphasized multilateral efforts to reengage Iran and work with allies on human rights and other sanctions program priorities, and spotlighted ransomware and virtual currency sanctions compliance issues and best practices.

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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