Recent designations and rulemaking expand the U.S. secondary sanctions architecture, raising the compliance bar for multinational financial institutions and corporates.
The Office of Foreign Assets Control has expanded the scope of its secondary sanctions program through a series of recent designations and an accompanying interpretive notice. Together, these developments materially increase the compliance obligations of non-U.S. financial institutions and corporates engaging in transactions touching designated sectors and jurisdictions.
Multinational institutions should anticipate further enforcement focus on transactional and counterparty due diligence, on the integration of sanctions screening with payment systems, and on board-level governance of sanctions risk.