On Monday (18 October 2021) the U.S. Department of Treasury released its 2021 Sanctions Review.
The report presents some welcome directions: enhanced multilateral coordination, avoidance of unintended consequences, clarity and reversibility, and the need to modernize.
But it also reminds us why sanctions implementation continues to be an enormous industry pain point, slowing customer on-boarding, creating friction in the payment chain, and creating a compelling need for new technologies and approaches.
A 933% increase in OFAC sanctions designations in the last 20 years!
