A post on the New York University School of Law’s “Compliance & Enforcement” blog notes that the US is increasingly going it alone with sanctions, in a “sharp departure” from the multilateral sanctions strategies favoured under the George W. Bush and Obama administrations, and that conflict of law presents global companies with a fast-changing and complex set of sanctions-related risks.  Policymakers are turning to sanctions with increasing frequency and launching programmes that are increasingly complex, and regulatory and enforcement agencies are devoting significant resources and attention to AML.  Strict distinctions among different categories of financial crime are starting to collapse, as an increasing number of sanctions programs and FinCEN advisories focus on issues such as corruption and misappropriation of assets by politically exposed persons (PEP).  The useful report reviews recent trends and developments in the Bank Secrecy Act, AML and sanctions regulatory landscape in the US from 2017 to the first half of 2019.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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