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ARTICLE · 03 NOVEMBER 2021

Treasury Publishes U.S. Sanctions Policy Review And Framework For Future Action

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At the end of last year, the incoming Biden-Harris administration announced that it was planning to conduct a comprehensive review of U.S. sanctions policy and implementation.

United StatesInternational Law
Wynn Segall
Wynn Segall
Mahmoud Baki Fadlallah
Mahmoud Baki Fadlallah
Nnedinma Ifudu Nweke
Nnedinma Ifudu Nweke
Jonathan Poling
Jonathan Poling
Elyse B. Martin
Elyse B. Martin
Katherine P. Padgett
Katherine P. Padgett
Johann Strauss
Johann Strauss
Andrew R. Schlossberg
Andrew R. Schlossberg
Omar Farid
Omar Farid
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Key Points

  • On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind "top to bottom" review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or concrete changes to existing sanctions programs. Rather, it provides a general framework for Treasury to use when considering imposition of new sanctions and recommendations for agency staffing enhancements to improve the near- and long-term effectiveness of sanctions measures.
  • The report also identifies emerging challenges to the efficacy of U.S. sanctions, including the proliferation of alternative payment systems and digital currencies that can enable malign actors to circumvent U.S. sanctions through the transfer and holding of funds outside the traditional dollar-based financial system.

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