U.K., EU enforcement regimes set to escalate, but critics question sanctions’ effectiveness

Global sanctions

Sanctions have escalated massively in U.K., EU and U.S. jurisdictions over the past three years. Organizations in these regions must keep up with, and abide by, constantly developing restrictions and penalties intended to prevent designated countries, regimes, and individuals from benefitting from international trade. While many target Russia, others focus on Iran, North Korea, and individuals and entities in a wide range of countries including China, Hong Kong, Turkey, and Kazakhstan. More are currently being imposed on groups on both sides of the conflict in the Middle East.

However, despite ongoing EU and British commitments to increasing the pressure of sanctions, including a new Office of Trade Sanctions Implementation in the U.K., some are questioning whether they are effective. There are further questions about U.S. President-elect Donald Trump’s intentions, since he has repeatedly promised to end the war in Ukraine, which is likely to involve ceding territory to Russia, and to put American trading interests at the forefront of all policies.

The U.S. Treasury Department’s Office of Foreign Assets Control is by far the most prolific imposer of sanctions–contributing 67 percent of net increases in designations across 18 sanctions programs in the first half of 2024, according to a recent report by LexisNexis Risk Solutions. With future American policy unclear, what should compliance managers expect in 2025 and how can they prepare their organizations in the face of such uncertainty?

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