The U.S. enactment in August of the Russian Sanctions Review Act significantly magnifies the risks from sanctions for international business and investment. The uncertainties created by tension between the President and Congress were themselves the catalyst in creating the platform to ramp up sanctions and limit Presidential autonomy in waiving them. The fast moving situation on the world stage seems to have moved the American political scene towards sanctions having bigger teeth, which will actually be used. In trying to predict the future course of sanctions enforcement in this short article, we focus on three key areas: (1) the widening of the net from sanctioned individuals to their families; (2) the application of the evasion provisions to foreign persons; (3) the bringing of new classes within existing sanctions.
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