Since our update in April of this year, the U.S. government has continued to aggressively modify and enforce its various sanctions programs. And this trend shows no signs of slowing in the months to come.
As in the first quarter of 2015, the last three months were marked by a combination of broad policy changes, individual designations and removals, and various enforcement actions. While recent developments did not include the overhaul of any sanctions program akin to the Cuba amendments in January, they did set the stage for significant changes in the future.
Here, we consider notable U.S. sanctions developments in the past quarter, and offer our thoughts on what is to come.