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Sanctions Pulse: Three Key Trends in Regulator Behaviour

2019 was yet another busy year in the area of international sanctions. We analysed sanctions data in order to ascertain what it can tell us about priorities in foreign policy. We found that:

  • Sanctions volatility reached a peak in 2019, primarily driven by an increase in updates to OFAC sanctions.
  • OFAC both intensified its use of pre-existing sanctions regimes in 2019 and also diversified, adding numerous new regimes.
  • The EU and other regulators have not followed suit, with increasing divergence in list size and priorities between OFAC and other major global sanctions programs.

To address the expanding scope of sanctions requirements, while tempering compliance costs and avoiding penalties, sanctions compliance practitioners need fast access to accurate data and sophisticated screening technology from a trusted source.

Sanctions can help governments advance respect for human rights, safeguard democratic institutions, and protect the financial system from illicit financial flows.

Saskia Rietbroek

Executive Director

Association of Certified Sanctions Specialists (ACSS)

Our analysis reveals trends in the use of sanctions for a wide range of foreign policy issues, from the political crisis in Venezuela to the international fight against terrorist groups. The numerous OFAC enforcement actions published in 2019 show just how critical it is for financial institutions and corporations to have an effective sanctions compliance process in place.

Vincent Gaudel

Compliance Expert