Economic sanctions and anti-money laundering (“AML”) remain at the forefront of U.S. regulatory priorities. Indeed, in 2017, federal and state agencies imposed over $2.5 billion in penalties for sanctions/AML violations. And, despite its generally deregulatory agenda, the Trump administration has taken a rigorous approach in this area, particularly with respect to sanctions. At the state level, the New York Department of Financial Services (“DFS”) continues to take aggressive action on both the regulatory and enforcement fronts. This memorandum surveys major developments and trends in 2017 and provides an outlook for the year ahead. We also provide some practical advice for U.S. and non-U.S. companies seeking to strengthen compliance and mitigate risk in this challenging environment.
Last year witnessed a number of dramatic changes to the economic sanctions landscape. President Trump has continued the recent trend of using economic sanctions as a powerful national security and foreign policy tool, and Treasury