Shearman & Sterling LLP
Issue link: https://digital.shearman.com/i/1422677
THIRD QUARTER 2021 (and a little extra) • OFAC releases "The Treasury 2021 Sanctions Review," identifying emerging challenges and recommending changes to modernize OFAC's approach to U.S. sanctions policy. • In "whole of government" approach, U.S. agencies caution against supply chain connections to Xinjiang and highlight new risks of operating in Hong Kong. • OFAC designates first crypto-currency exchange for supporting cyber-criminals, signaling more actions to come, and offers compliance guidance specifically for the "virtual currency industry. • U.S. applies sanctions pressure in support of Cuban di ssidents, whi continuing to target military leaders in Myanmar. • Numerous OFAC enforcement actions against U.S. financial-servic and energy firms demonstrate need for strong controls on intra- corporate dealings with non-U.S. affiliates. " le e