2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic Sanctions to discuss lessons learned and predictions for the year to come. The conference featured officials from numerous agencies, including the Department of Justice’s National Security Division (NSD), the Treasury Department’s Office of Foreign Asset Control (OFAC) and Financial Crimes Enforcement Network (FinCEN), and the Commerce Department’s Bureau of Industry and Security (BIS). Key themes included:
- use of export controls as an increasingly key compliance tool;
- enhanced cooperation among agencies and allies abroad;
- increased engagement between regulators and the private sector, including voluntary self-disclosure and whistleblower programs; and
- enforcement focus on technology and other new areas.
