“‘In financial services, people are very accustomed to these sanctions,’ Ms. Rosenberg said. ‘There’s a lot of existing knowledge about what it means to have sovereign debt restrictions, correspondent banking restrictions.’

“‘But when there are new measures that go at nonfinancials—which is an expressed goal of this administration, for example, in the shipping industry, other manufacturing areas—that is a new compliance challenge for many industries, who haven’t seen this kind of measure being handed out before, and who may not have, in many instances, the compliance programs and the awareness, the in-house and external legal counsel, the subject matter expertise on their staff or immediately available to them to understand and immediately react…’”

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