US Sanctions Efforts Trending Toward Transnational Crime, Law Firm Says

Recent U.S. sanctions against an Iranian procurement network and drug traffickers in Mexico signal a trend within the Biden administration toward using sanctions to target “transnational organized crime,” Herbert Smith said in a June client alert. The firm suggested that companies should make sure their anti-money laundering and “know your customer” procedures are incorporated as “an integral part of sanctions compliance” due to the U.S.'s “increasing sanctions focus on transnational crime and money laundering.”

The firm pointed to several recent sanctions announcements, including the Treasury Department’s designation earlier this month of people and entities in China, Hong Kong and Iran for helping Iran procure parts and technology for its ballistic missile programs (see 2306060043). The firm also pointed to OFAC’s sanctions this month against three people and one entity with ties to Mexico’s Cartel de Jalisco Nueva Generacion (see 2306060035).