THE SANCTIONS GLOBAL LANDSCAPE IS MORE COMPLICATED, CHALLENGING & INCONSISTENT THAN EVER BEFORE

April 22, 2020

The Sanctions global landscape is more complicated, challenging and inconsistent than ever before and, alongside this scenario, regulatory compliance and scrutiny continues to increase.

In September 2017, there were 21,091 total explicit sanctions across 231 sanctions programs issued by 38 countries or international/regional bodies.

By February 2020, this number had grown to 34,155 (a 62 percent increase) across 281 sanctions programs issued by 50 countries or international/regional bodies.

Certainly a great deal of this increase was down to a sharp rise in the number of sanctions from the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) over the period.

Additionally, many sanctions have also been subject to ongoing additions, deletions and amendments, adding significantly to the organizational compliance burden.
The last few years have not only been characterized by increases in sanctions-related activity, but also by divergent sanctions regimes across the globe.

A clear rise in national sanctions has seen the U.S. as the most prolific implementer, but not the only regulator, the EU remains a major sanctions legislator as well.

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April 22, 2020