Sanctions programs operate a lot like software: small revisions can produce significant downstream effects, and the “runtime” is spread across statutes, executive orders, regulations, and agency guidance.

When comparing versions, it helps to focus on a few questions:

• Scope: who and what is covered, including definitions, covered activities, and jurisdiction.
• Delegation: which agencies gain or lose authority.
• Exceptions: licensing pathways, carve-outs, and compliance safe harbors.
• Timing: effective dates, wind-down periods, and reporting requirements.

A redline helps reveal how the legal architecture changes over time.