International Law and Immigration

Ca. Int'l Law Journal VOL. 25, NO. 1, FALL 2017

The ‘Don’ of a New Era: Untangling the Sanctions Policy of the Trump Administration and its Compliance Implications

By Saskia Rietbroek and Anna Sayre*

On November 8, 2016, the American voters chose to elect Donald J. Trump as the 45th President of the United States. No matter what your opinion about the outcome of the election, the billionaire and former reality TV star has changed the face of American political norms and signaled a possible departure from existing foreign policy and sanctions law.

Being properly prepared for such changes is essential to those in the sanctions and trade controls fields as it could have a broad impact on compliance duties and day-to-day responsibilities. Sanctions lawyers and compliance officers in the U.S. and abroad must keep one step ahead of any changes to economic sanctions policy that the Trump administration can be expected to establish and implement.

This article will endeavor to unravel the comments and assertions made by President Trump and his top assistants concerning economic sanctions and export controls so that legal and compliance professionals may make informed decisions as to the likely positions of the new administration during the next four years. Our analysis will focus on four countries on the forefront of current sanctions policy: Iran, China, Russia and Cuba.

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