The following post was originally included as part of our recently published memorandum “Selected Issues for Boards of Directors in 2022”.
U.S. sanctions policy in the first year of the Biden administration saw both change and continuity. As expected, the administration sought to cooperate with allies to impose multilateral (rather than unilateral) sanctions, focused on human rights abuses and opened the door for a new nuclear deal with Iran. At the same time, the administration continued to focus on virtual currencies and on combating illicit cyber activities relating to ransomware, and clarified (and in some respects expanded) sanctions issued under the Trump administration targeting Chinese companies deemed to be part of the Chinese military-industrial complex.
In 2022, boards of directors should be aware of continued regulatory focus on virtual currencies and ransomware, potential divergences and conflicts across new global sanctions regimes and potential sanctions developments relating to Russia, Iran and China.
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For a PDF of the full memorandum, please click here.