In an article in their series examining important trends in white collar law and investigations in the coming year, attorneys at Foley Hoag look at export controls and sanctions, which they describe as a “whirlwind” that shows no signs of slowing down in 2020. Their predictions include:
- OFAC will continue to focus on key sanctions programs, involving Iran, Russia, Turkey, Syria, Cuba, and Venezuela, and an increase in sanctions being used to defend against or punish human rights violations, such as in China.
- New technology export regulations will be a focus, again involving China, with Huawei now on the Bureau of Industry and Security’s Entity List.
- Regulators will continue efforts to provide guidance on compliance and voluntary disclosure of violations.
- Sanctions and export control enforcement will remain a top priority for regulators
