U.S. sanctions authorities remained active in the first quarter
of 2020, even as international focus turned toward combatting the
COVID-19 pandemic. OFAC and the U.S. State Department imposed
secondary sanctions on firms in China and elsewhere for continued
dealings with Iran. Meanwhile, the Trump Administration authorized
new sanctions on Iran's construction, mining, manufacturing,
and textile sectors, and ratcheted up restrictions on the
country's largest metals manufacturers. In response to
Iran's continued uranium enrichment efforts, Europe's JCPOA
signatories triggered a dispute mechanism to try and save the
nuclear agreement. Elsewhere, OFAC blacklisted two Rosneft
subsidiaries in an attempt to curb Russia's support for
Venezuela's oil trade. Finally, a Swiss technology firm's
settlement with OFAC illustrates the sanctions risks to non-U.S.
companies using U.S. origin technology.