Shearman & Sterling LLP
Issue link: https://digital.shearman.com/i/1422677
8 sanctions, OFAC will first ask whether a sanctions action supports a clear policy objective within a broader foreign policy strategy of the United States. 2. Wherever possible, work in multilateral coordination, as sanctions are most effective when coordinated within an Administration and with international allies and partners. Interagency and international coordination, the Review posits, can magnify the economic and political impact, and has the added benefit of enhancing the credibility of U.S. leadership. 3. Ensure that each sanctions action is carefully tailored and calibrated to mitigate unintended economic, political, and humanitarian impact. Sanctions actions should aim to ensure that the impacts are felt by the intended sanctions targets and minimize, to the greatest extent possible, adverse impacts to the U.S. economy, our allies, and other third-parties. 4. Ensure that sanctions are easily understood, enforceable, and, where possible, reversible. The Review indicates that OFAC can improve existing outreach efforts by expanding engagement with industry, financial institutions, allies, civil society, and the media, as well as new constituencies. 5. Modernize OFAC's sanctions technology through investment in technology, workforce, and infrastructure. Spotlighting the evolving digital assets and services space, the Review observes that robust enforcement requires enhanced technology and a workforce with deeper institutional knowledge. As criminals are quick to exploit innovations and new technologies to effect their illegal activities, the Review concludes that the need for OFAC to adapt to evolving landscapes is paramount.