The following is part of our annual publication Selected Issues for Boards of Directors in 2025. Explore all topics or download the PDF.
The second Trump Administration is expected to mark the return of a more transactional foreign policy approach, with an openness to dealmaking supported by the aggressive use (or threat) of trade controls. Boards should, therefore, expect the U.S. government to continue to rely on trade controls as a key foreign policy tool. Although specific actions remain uncertain, significant change is possible on a number of fronts, including sanctions relating to China, Russia, Iran, Syria and Venezuela.
2024 was an active year in U.S. trade controls against Russia and China in particular. In addition to the continued designations of individuals and entities, foreign financial institutions (FFIs) faced heightened secondary sanctions risks with respect to Russia, and companies dealing with semiconductors, microelectronics and other advanced technologies faced additional restrictions relating to China. Also, the statute of limitations for U.S. sanctions violations increased from five to ten years, exposing companies to greater enforcement risk for historical conduct