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The pandemic and its impact is the story of 2020 – no doubt. Federal prosecutors and regulatory enforcement agencies faced unprecedented challenges.
In the face of these challenges, however, enforcement almost across the board continued with some significant exceptions relating to individual criminal enforcement. Prosecutors faced almost impossible obstacles to convening grand juries and conducting court proceedings while the deadly pandemic raged.
Despite the challenges facing OFAC during the pandemic and the strain on resources, OFAC continued its dogged commitment to sanctions enforcement. While the numbers racked up by OFAC were lower because of the pandemic, OFAC later in the year resumed its aggressive pace of sanctions enforcement. It even released two enforcement actions during the week between Christmas and New Year’s.