Sanctions Round Up: Second Quarter 2021

This quarter, the Biden Administration maintained its tough stance on China, revamping Trump-Era restrictions and expanding sanctions to include the PRC's surveillance technology sector. In contrast, the Administration reversed years of U.S. Congressional policy by waiving key Nordstream 2 sanctions, effectively dropping U.S. opposition to the pipeline's completion. While the U.S. and Iran continued indirect talks in Vienna to explore reviving the JCPOA, a European court's interpretation of the EU blocking statute portends further challenges for European operators seeking to align their commercial dealings with U.S. extra-territorial sanctions. Elsewhere, the U.S. continued efforts to cut off vital sources of revenue to Myanmar's military, sanctioning several state-owned enterprises. Finally, the Department of Justice secured its first settlement pursuant to its new "Export Controls and Sanctions Enforcement Policy."