August 2023 - Diego Durán de la Vega and Anna Hamati co-authored a chapter in Latin Lawyer’s Guide to Corporate Compliance on recent trends in mitigating U.S. sanctions risks in Latin America.

In the chapter, Durán de la Vega and Hamati provide an overview and analysis of trends in U.S. sanctions regulatory developments and enforcement actions. Specifically, the authors highlight recent actions in Nicaragua, Paraguay, Venezuela and Russia that illustrate how the U.S. government utilizes sanctions to isolate persons acting contrary to its interests from the U.S. financial market, as well as the government’s willingness to lift sanctions when a sanctioned party shows an interest in meaningfully engaging with U.S. government interests and discontinuing its malign behavior.

The authors then highlight the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recent civil penalty enforcement actions for sanctions violations, emphasizing its increased focus on the “causation” theory, and OFAC’s enforcement of secondary sanctions by adding individuals and entities acting against U.S. interests to its Specially Designated Nationals and Blocked Persons List.

The chapter concludes by highlighting recent sanctions trends, including the increase in coordinated sanctions actions across multiple jurisdictions and enforcement actions against non-U.S. persons who involve the U.S. financial system in sanctionable activity.  

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