Enforcement Trends 2025.
As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to speculate about the year ahead. While each regulator was careful to say they did not have a crystal ball view into what the future holds, there was universal agreement that sanctions and export controls will remain powerful enforcement tools, and the machinery that has increased inter-agency coordination is likely to remain in place.
Below we highlight key observations from the Justice Department’s National Security Division (NSD), the Commerce Department’s Bureau of Industry and Security (BIS), and the Treasury Department’s Office of Foreign Asset Control (OFAC) and discuss how companies can best position themselves in this time of transition. Highlights include:
- Continued close coordination among agencies
- Increasing focus on technology
- Evolving application of sanctions approaches
- Role of cryptocurrency
- OFAC’s efforts to modernize
