In last month's newsletter, we discussed how developments in
2012 had considerably tightened sanctions against Iran, including
through the first-ever application of sanctions to separately
incorporated subsidiaries of U.S. multinational companies. In this
second part of our year-end review, we discuss how other sanction
regimes changed in 2012, including in ways that present both
business opportunities (where sanctions have eased) and compliance
challenges (where sanctions have been newly imposed or have
tightened).
The past two years have witnessed substantial changes in the
scope and effect of U.S. economic sanctions. In most instances,
such as Iran and Syria, the result has been more aggressive,
comprehensive, and extraterritorial regulation. But in other cases,
the trend was toward a calibrated easing of restraints in countries
undergoing constructive social and political change. From
empowering civil society groups in Burma, to supporting to
transitional
