By David Mortlock
December 23, 2015

The U.S. government has developed unprecedented new measures over the past half decade:  the use of secondary sanctions on Iran; the easing of sanctions on Burma in a way that continues to encourage policy goals; and the restrictions on financing on Russia.  This increased sophistication makes sanctions a more calibrated and cost-effective tool for government, but also puts a greater burden on the private sector to comply with increasingly complex restrictions.  Sanctions also place an exceptional burden on the private sector because they are driven, not by regulation of an industry, but by foreign policy crises. As a result, changes are less predictable and the interests and motivations of the government may not be immediately obvious to private actors. The next Administration, whether Republican or Democrat, will almost certainly turn to sanctions with increasing frequency.