In recent years, the U.S. has expanded the use of sanctions as a modern-age foreign policy tool to avoid warfare, while exerting influence over individuals and entities that, in theory, threaten or impinge on U.S. interests. Economic sanctions are proliferating at a speed never before seen, and the U.S. leads the way by issuing new sanctions almost daily against targets it believes are connected to Russian and Chinese interests. However, if you are the target of a sanction, it is in fact not the end of your business or economic life. Managing Partner Robert W. Seiden, who focuses on economic sanctions matters, has given his insights on navigating conversations with government agencies regarding sanctions list removals and licenses.
The U.S. Department of the Treasury’s Office of Foreign Assets Control has sanctioned approximately 2,400 people or businesses believed to have Russian ties in order to degrade Russia’s capacity to successfully conduct its war against Ukraine in the past year. Additionally, according to OFAC sanctions data, there are currently 1,133 sanctions against citizens and businesses of Iran, 641 against those in Syria and 477 against those in China. Mr. Seiden discusses how, contrary to common belief, “though sanctions are not going away anytime soon, they can be ameliorated or removed, provided communication with OFAC is credible and meaningful, and not defensive.”