Sanctions Advisory’s Post

Partner Paul Feldberg is one of six editors of the GIR's Guide to Sanctions which is now in its 5th Edition. In this edition Paul Feldberg and associate Menelaos Karampetsos have provided a comprehensive overview of #sanctions in the United Kingdom. As corporations and individuals across the globe are having to comply with an unprecedented number of financial sanctions and export control restriction Paul Feldberg and Menelaos Karampetsos have sought to provide a practical guide as to how individuals and companies should comply with UK law. With governments now turning from imposing sanctions and export controls to enforcing those restrictions, there is an increasing need for companies and individuals to ensure they are compliant - see the Chapter here: https://lnkd.in/epgHHs5c For the complete guide, see the link here: https://lnkd.in/exgXc9Af

🚨 FAQ Alert The EU’s 14th sanctions package against Russia introduced the so-called “best efforts” requirement, which obliges EU businesses to prevent their non-EU subsidiaries from undermining EU sanctions. ➡️ In its latest Frequently Asked Questions (FAQ), the European Commission has significantly expanded these obligations and the associated liabilities for EU businesses, pushing the boundaries of extraterritoriality. While the FAQ will inevitably be “tested” by EU jurisprudence and National Competent Authorities, one thing is clear: the Commission expects EU businesses to enhance their compliance efforts at both headquarters and subsidiary levels. To meet these expectations, EU companies must conduct robust risk assessments and implement comprehensive compliance policies and programmes. Failure to do so could result in violations of Article 8a or Article 12 of Council Regulation 833/2014. Below, we’ve highlighted key takeaways from the FAQ, and you can access the full FAQ here: https://lnkd.in/dVKzRMBA #EUsanctions #EuropeanCommission #Sanctions #FAQ #Liability #Compliance

We have provided an updated chapter on the UK Guide to Sanctions in the GIR Guide to Sanctions. Keeping the Guide to Sanctions updated is a mammoth task, given the constant blizzard of new restrictions, guidance and case law -much of which remain inconsistent across different jurisdictions (and even within jurisdictions!). The updates could not be achieved without the yearly work of the law firms involved and the indefatigable editors: Anna Bradshaw; Rachel Barnes KC; David Mortlock;Anahita Thoms and Wendy Wysong.

📢 Important update on EU sanctions enforcement from the Netherlands The Dutch government just released a compelling non-paper proposing key reforms to strengthen EU sanctions implementation and enforcement. As sanctions remain critical in responding to Russia's aggression against Ukraine, this initiative couldn't be more timely. Key proposals: Creating an EU-wide risk assessment system for sanctions circumvention Establishing clearer standards for national enforcement Setting up a private sector sounding board to improve compliance Developing better support tools for SMEs Introducing baseline compliance rules for high-risk businesses This is a crucial step toward ensuring sanctions actually achieve their intended impact. The paper recognizes that while Member States lead enforcement, we need stronger European cooperation and harmonization to prevent exploitation of weak links. Particularly interesting is the focus on helping businesses comply through practical tools like a "due diligence helpdesk" and better guidance - acknowledging that most companies want to follow the rules but need support to navigate complex requirements. #EuropeanUnion #Sanctions #Compliance #InternationalTrade #RegulatoryCompliance What are your thoughts on these proposals? Would love to hear perspectives from compliance and legal professionals.

📢 Important update on EU sanctions enforcement from the Netherlands The Dutch government just released a compelling non-paper proposing key reforms to strengthen EU sanctions implementation and enforcement. As sanctions remain critical in responding to Russia's aggression against Ukraine, this initiative couldn't be more timely. Key proposals: Creating an EU-wide risk assessment system for sanctions circumvention Establishing clearer standards for national enforcement Setting up a private sector sounding board to improve compliance Developing better support tools for SMEs Introducing baseline compliance rules for high-risk businesses This is a crucial step toward ensuring sanctions actually achieve their intended impact. The paper recognizes that while Member States lead enforcement, we need stronger European cooperation and harmonization to prevent exploitation of weak links. Particularly interesting is the focus on helping businesses comply through practical tools like a "due diligence helpdesk" and better guidance - acknowledging that most companies want to follow the rules but need support to navigate complex requirements. #EuropeanUnion #Sanctions #Compliance #InternationalTrade #RegulatoryCompliance What are your thoughts on these proposals? Would love to hear perspectives from compliance and legal professionals.

We are only 2 days away from this exciting program! The second session of the #YoungITATalks "𝐆𝐥𝐨𝐛𝐚𝐥 𝐒𝐮𝐩𝐩𝐥𝐲 𝐂𝐡𝐚𝐢𝐧𝐬: 𝐍𝐚𝐯𝐢𝐠𝐚𝐭𝐢𝐧𝐠 𝐒𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐬" is entitled "𝑵𝒂𝒗𝒊𝒈𝒂𝒕𝒊𝒏𝒈 𝑺𝒂𝒏𝒄𝒕𝒊𝒐𝒏𝒔 𝒂𝒏𝒅 𝑻𝒉𝒆𝒊𝒓 𝑬𝒇𝒇𝒆𝒄𝒕 𝒐𝒏 𝑮𝒍𝒐𝒃𝒂𝒍 𝑺𝒖𝒑𝒑𝒍𝒚 𝑪𝒉𝒂𝒊𝒏𝒔". This session features moderator Benan Arseven (MOROGLU ARSEVEN) and speakers Maria Fogdestam Agius (Westerberg & Partners), Young ITA UK Co-Chair, Robert Bradshaw (LALIVE), and Roman Zykov (Mansors ). Supply chains for many businesses now span the globe – and, more and more, so do international sanctions. Governments have progressively turned to sanctions as tools of foreign policy and national security, enacting sweeping export controls and financial restrictions against an ever-expanding list of entities and individuals. At the same time, the extraterritorial reach of these sanctions has continued to grow. As authorities now look to target sanctions circumvention, sanctions compliance is no longer only a concern for businesses in the US or EU. Sanctions, like trade, have undergone their own form of globalization. For more information, and to register, click here: https://lnkd.in/dhZxe3es

Global #sanctions – differing approaches to the provision of services In this article, read about the different positions of the: ✔ UK ✔ US ✔APAC Sanction measures by various states have sharply increased in recent months. Foreign policy objectives play a crucial factor in countries’ decisions regarding their varying approaches. In a year when elections continue to take place across multiple countries, any change in government could result in a shift in approach and future policy towards Russia and its relations with foreign governments. This means that carrying out #duediligence and #risk assessments in light of the rapidly changing landscape will be key for businesses and insurers operating across different jurisdictions. Ensuring #compliance with the relevant international trade sanctions and regulations and mitigating regulatory and legal risks to businesses will become increasingly important. Sanctions against Russian entities will likely continue to evolve and, in some cases, be aggressively pursued in respect of secondary sanctions on those who indirectly provide support through goods or services. This evolving landscape does, however, depend on what any new governments consider their global #trade relationship priorities to be. Thank you, Iskander Fernandez and Joanna Manthorpe for ✍ this article. https://lnkd.in/ecGSZ225

In my last two posts, I elaborated on the EU and UK's sanctions policies toward Russia and how they are aligning closer with those of the US. This recent article from Steptoe & Johnson LLP further explores the growing convergence between the sanctions frameworks of the UK, EU, and Canada with the US. This alignment seeks to strengthen global compliance efforts in an increasingly complex geopolitical environment. For financial institutions and businesses operating internationally, staying informed on these evolving policies is essential for maintaining compliance and minimizing risks. #GlobalCompliance #SanctionsPolicy #SanctionsCompliance #ComplianceRisk #RussiaSanctions

15th Sanctions Package Against Russia | Regulatory Capsule Powered by: Transact Comply This week, we review the EU's 15th Sanctions Package adopted by the European Commission Read More: https://zurl.co/U51u1 Product Insights: https://zurl.co/E0MW #EUSanctions #RussiaSanctions #UkraineSupport #GlobalSanctions #AssetFreezes #Geopolitics #BelarusSanctions #NorthKoreaSanctions #SudanConflict #HaitiCrisis #DualUseRestrictions #EURegulations #EconomicMeasures #NoLiabilityClause #SanctionsCompliance

💡 Do you know how sanctions are created and enforced? Sanctions are not just rules on paper; they represent a global effort to enforce accountability and protect international standards. 🌍 🔹 Who imposes sanctions? Governments and intergovernmental organizations, like the UN and EU, impose sanctions through laws, regulations, and resolutions (e.g., "restrictive measures" in the EU). However, enforcement requires action at the domestic level. 🔹 How are sanctions enforced? Member nations adopt and implement sanctions through domestic regulatory bodies. In the US, for example, Congress passes sanctions, while agencies like OFAC monitor compliance. Financial institutions and private actors are often required to enforce sanctions, with non-compliance leading to fines or penalties. 🔹 Who benefits from imposing sanctions? Studies show sanctions are more effective when imposed by countries with a GDP at least 10x larger than the target. Larger, wealthier nations often have the resources to enforce and sustain these measures. Sanctions are a collaborative effort requiring global alignment, domestic enforcement, and private sector accountability. 💼 💬 How can smaller countries or organizations ensure compliance without overburdening their systems? #Sanctions #GlobalPolicy #InternationalLaw #AML #Governance #FinancialCrime