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The New Era of Regulatory Enforcement: A Comprehensive Guide for Raising the Bar to Manage Risk by Timothy P. Hedley, Richard H. Girgenti

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Chapter 5

Economic and Trade Sanctions

Charles M. Steele

The U.S. government is using economic and trade sanctions more expansively and aggressively than ever before. The government increasingly looks to sanctions as a primary tool of foreign policy and national security, as demonstrated by its actions over the past several years relating to Iran and, beginning in March 2014, to Russia’s activities in Ukraine. And the government is also enforcing sanctions violations more aggressively than ever, bringing civil monetary penalty actions—and, in some cases, parallel criminal cases—against companies that do business with sanctioned persons and entities.

Over the past few years the U.S. Department of the Treasury’s Office of Foreign Assets Control ...

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