Sanctions

We have market-leading expertise in advising our clients on sanctions. We provide businesses impacted by sanctions with commercially focused advice and support, often in difficult circumstances.

We also represent major commercial companies and businessmen in challenging sanctions in national and EU courts.
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Financial and trade sanctions are an increasingly common and powerful foreign policy tool. Their implementation exposes businesses and individuals to huge financial, criminal, reputational, political and regulatory risk. Our sanctions team offers an international outlook on the legal and practical implications of sanctions.

As well as advising generally on sanctions interpretation and compliance, we advise on the licensing regimes and have dealt with competent authorities in a number of jurisdictions within EU member states and offshore jurisdictions.

We have also acted for sanctioned entities and individuals in more than 20 cases challenging sanctions in national and EU courts. These cases often involve novel issues of law in a fast-moving and politically charged environment. Several are cited by others in interpreting EU sanctions regimes.

Our experience acting for those targeted by sanctions as well as businesses otherwise impacted enables us to provide our clients with a complete legal and commercial picture when interpreting a sanctions regime.

"A terrific team involved in some of the most cutting-edge work in the public law arena. The level of service rivals the magic circle city firms, and expertise in this area is second-to-none."

The Legal 500 UK 2020

UK and EU sanctions targeting Russia (2022)

As a consequence of Russia's recent illegal invasion of Ukraine, the international community has swiftly imposed wide-ranging sanctions on Russia.  They are extremely complex and rapidly changing – often more than once a day.  We have been advising a broad range of clients on their impact to their businesses including aviation financiers, funds and asset managers, fiduciary service providers, maritime service providers, management companies and insurers.  We have also been engaged by other law firms to provide sanctions advice to their clients.

Motor racing company

Advising a motor racing company on its rights arising out of a financial institution's decision not to allow its customers (who were suppliers to the motor racing company) to receive payments from the company based on a mistaken belief that the company was associated with individuals and entities subject to OFAC asset freezes.  Our representation resulted in a prompt reversal of the relevant financial institution's position with payments flowing once more.

Financial institutions

Advising our clients on the effects of the EU sanctions imposed against Russia in 2014 in relation to Ukraine.

Iranian, European and Asian banks

Advising our clients on the interpretation of EU and UK sanctions against Iran in relation to existing and proposed finance transactions, including restructuring and acceleration of loan facilities and enforcement.

US equipment finance and leasing company

Advising in respect of the sanctions related wording to be contained in various commercial contracts within certain of their joint venture arrangements.

Libya sanctions

Advising UK hedge fund and Libyan owned UK bank on complex international issues involving UN, EU, UK, Dutch, Swiss and offshore sanctions against Libya.

UK manufacturing company

Advising a UK manufacturing company on sanctions concerns raised as part of the due diligence undertaken by its proposed purchaser, a US based company.

Korean shipping company

Advised this shipping company, with operations worldwide, on the effect of US, EU and UK sanctions against Iran on chartered vessels transferred to a US controlled company as part of a multi-million dollar acquisition of a fleet of vessels.

Leading Iranian ship owner

Advising in relation to sanctions against Iran, including advising on European based finance/loan obligations, charter party and MOA obligations and shipbuilding contracts.

Iranian, European and Asian shipping companies

Advising our clients on the effect of US, EU and UK sanctions against Iran on their ongoing business operations and sanctions policies and procedures.

Latest news & insights

23 Jul 2024

From Insights

High Court orders scent-sational board reshuffle over director's breach of the UK's Russia sanctions for exporting perfumes

In Garofalo v Crisp [2024] EWHC 1737 (Ch), the High Court continued an ex parte injunction which removed a director from the board of a luxury perfume group, after fin..

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05 Jul 2024

From Insights

EU's 14th sanctions package against Russia: an expanded approach to jurisdiction

The EU's 14th package of sanctions against Russia, which entered into force on 24 June 2024, takes an expansive, United States-style approach to jurisdiction and circu..

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17 Jun 2024

From Insights

Court of Appeal provides clarity on the UK's Russia Regulations and actions taken for sanctions compliance under section 44 of SAMLA

In Celestial Aviation Services Limited v Unicredit Bank AG, London Branch [2024] EWCA Civ 628, the Court of Appeal considered the scope and application of: Regulation ..

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17 Jun 2024

From Insights

All fingers and thumbs – protections against a "fat finger" moment

On 17 May 2024, the FCA published a Final Notice against CitiGroup Global Markets Limited ("Citi") in relation to the FCA's findings in relation to Citi's control fail..

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04 Jun 2024

From News

Sanctions risk... you have been warned!

In response to the Russian Federation's ongoing conflict with Ukraine, the United Kingdom and the European Union have introduced extensive financial and trade sanction..

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11 Aug 2023

From Insights

Incoming restrictions on US investments into China's technology industries 美国对华科技领域投资监管限制即将出台

The US government is introducing controls and restrictions on US investment into Chinese technology.

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22 May 2023

From Insights

Section 44: fig leaf or shield?

In a short but important judgment (Celestial Aviation Services Limited v Unicredit Bank AG, London Branch [2023] EWHC 1071 (Comm)), the Commercial Court has, for the f..

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23 Dec 2022

From Insights

UK and EU sanctions: expansion of the professional and business services prohibitions

In this article, we set out the new scope of the UK's ban on professional and business services contained in the 17th Amendment, and compare it with EU Regulation 833...

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19 Dec 2022

From Insights

UK/Russia trust sanctions: a neat trick or creating new potential problems?

Many months after the Government first announced its intention to introduce Russia related trust sanctions, they have finally been published in The Russia (Sanctions) ..

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11 Nov 2022

From Insights

UK sanctions: prohibition on the maritime transportation of crude and petroleum oil and products

On 5 December 2022, the 16th amendment1 to the UK's sanctions against Russia, The Russia (Sanctions) (EU Exit) Regulations 2019 (the "Regulations")2, comes into force ..

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10 Nov 2022

From Insights

UK sanctions: Russian-owned customers? Beware extended payment terms

The UK has recently amended its sanctions regime against Russia, The Russia (Sanctions) (EU Exit) Regulations 2019 (the "Regulations"), for the 15th and 16th times thi..

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22 Jul 2022

From Insights

UK sanctions: professional and business services to Russian clients

On 4 May 2022, the UK Government announced a ban on services exports to Russia, stating: "The new measures will mean Russia’s businesses can no longer benefit from the..

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15 Jul 2022

From Insights

Sanctions: UK to introduce new sanctions targeting Russian connected trusts

Following the EU's introduction of sanctions against EU trust and company service providers ("TCSPs") in May 2022, the UK government has now announced that it will fol..

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29 Jun 2022

From Insights

EU sanctions: European Commission guidance on trusts measures

On 8 April 2022, the EU added Article 5m to Regulation (EU) No 833/2014 (the "Regulation") as part of the 'fifth package' of EU sanctions against Russia.

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16 Jun 2022

From Insights

UK and EU sanctions: recent developments

In this article, we look at some of the other elements of Regulation 2022/879, together with recent strengthening to the penalties for breach of sanctions in the UK an..

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09 Jun 2022

From Insights

EU sanctions: tweaking sanctions against trusts

The 'sixth package' of EU sanctions against Russia was adopted on 3 June 2022. While the sanctions on Russian oil have grabbed the headlines, the EU has also taken th..

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