Having historically targeted banks, OFAC shows interest in penalizing banks’ customers that send illegal payments through the U.S. financial system. OFAC’s action is significant because it appears to be the first time the entity penalizes a non-U.S., non-financial company for “causing” sanctions violations by initiating U.S. dollar payments involving a sanctioned country. Read more here. Ms.…

In the last few years, drastic liberalization has changed the comprehensive U.S. sanctions against Iran and Cuba that had been maintained for decades. Iran sanctions were first enacted in 1979 (with the broad secondary sanctions for foreign subsidiaries only in place since 2012). Cuba sanctions began in 1960. Garnering less fanfare, the U.S. also largely…