Overview
Bloomberg Government quoted Jack Hayes in a June 7 article titled "Surge in Sanctions Enforcement Reflects Treasury Unit’s Backlog." The article discusses how companies doing business with sanctioned foreign entities have already been hit with $1.28 billion in US government fines and settlements this year, which is higher than any year-end total in at least a decade. According to the article, more fines could be in the works. Cases related to recent sanction designations tied to high risk-countries such as Iran have likely not made their way through the Office of Foreign Asset Control's often lengthy review process.
Hayes says: "With Iran, there hasn't been a dramatic uptick of sanctions enforcement cases recently, nor have there been any secondary sanctions imposed against foreign persons" since November 2018. "But I think it's safe to say that those reviews are underway."
The full article can be read at Bloomberg Government (subscription required).