Compared to prior years, this first half of 2021 has seen a drop in the number of published enforcement actions by  the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). The reduction is likely attributed to  the new U.S. administration’s desire to realign and refocus its sanctions programs. The remainder of 2021, and  perhaps through the current administration’s term, is likely to see an increase in published enforcement actions.  Notwithstanding, there are still some notable enforcement actions this year, including the first-ever resolution  pursuant to the U.S. Department of Justice’s (DOJ) Export Control and Sanctions Enforcement Policy for Business  Organizations.

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