In two separate rounds of sanctions designations in the past week, the United States added more parties to the Specially Designated Nationals List (“SDN List”) maintained by the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. These designations are noteworthy given their scope and, in the case of the Iran-related designations, the fact that they included parties in China, Russia, and Türkiye. Not only does this increase the risk of encountering sanctioned…