US Export Controls And Economic Sanctions Enforcement – Seven Trends To Watch In 2018


Issue 65 | December 2017

In this article, Timothy O'Toole discusses the 2017 export controls and sanctions developments and what they may mean for businesses and practitioners in 2018. "Trying to predict US export controls and economic sanctions enforcement trends can be a slippery business, especially when the leadership at US enforcement agencies is going through a period of significant change. Nonetheless, based on what we have already seen from the new administration, and what we have consistently seen over the past few years from the US government's export controls and economic sanctions enforcement agencies, the following seven trends seem likely to dominate the export controls and sanctions landscape for the foreseeable future," O'Toole wrote. His seven trends to watch include how the Trump administration will approach the Joint Comprehensive Plan of Action (JCPOA); broadened industry focus by enforcement agencies; increasingly expansive theories of US export controls and sanctions jurisdiction; greater enforcement of Russia sanctions; growing enforcement actions involving China; continued focus on name and address screening; and challenges and heightened diligence for multinational transactions.