With the changing of the POTUS guard, it is an appropriate time to check on the State of OFAC sanctions SDN designations since just before the last time the changing of the guard occurred. The following charts are from June 2015 and January 2021 respectively, and they show OFAC SDN designations increased 150%! (Please see: http://ofacanalyzer.com/rptListTotals.aspx).
This 2021 blog (as opposed to prior current event blogs at: https://thesanctionsgeek.com/blog/) will focus on practical challenges businesses face in complying with the ever dynamic sanctions laws given this uptick in designations. The increase does not appear to be an aberration of the Trump administration. Already with newly installed President Joe Biden talking tough via phone with Vladimir Putin and exclaiming the POTUS will have no reason to hold summits with Kim Jung Un unless North Korea denuclearizes first, the state of continued OFAC designations promises to be alive and well for the foreseeable future.
Crafting a proper set of policies and procedures to comply with sanctions laws will be mission critical, not to mention the proper selection of screening software, the proper resolution of potential matches, the ability to impose transaction stops in a timely manner as well as dealing with the new OFAC reporting requirements.
