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.
  • Profile
  • Experience
  • Key contacts

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.

Lawyer

Sue Millar Partner

T:  + 44 20 7809 2329
M:  + 44 7825 625 898 Email Sue | Vcard Office:  London

Latest news & insights

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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10 May 2022

From Insights

EU sanctions: application of trusts measures outside the private trusts sphere

As noted in our recent article, the 'fifth package' of EU sanctions against Russia adopted on 8 April 2022 introduced a notable addition to Regulation (EU) No 833/2014..

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14 Apr 2022

From Insights

EU sanctions: impact on the trust industry

The EU has expanded its sanctions against Russia by introducing restrictive measures, prohibiting EU trust and company service providers ("TCSPs") from providing admin..

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18 Mar 2022

From Insights

Key changes to UK sanctions regime - The Economic Crime (Transparency and Enforcement) Act 2022

On 15 March 2022, the Economic Crime (Transparency and Enforcement) Act (the "ECA") received Royal Assent after being fast-tracked through Parliament in response to th..

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16 Jun 2021

From Insights

Sanctions wave intensifies compliance headaches

In an article published by The Banker, Stephenson Harwood of counsel Stephen Ashley shares his insights on the difficulties faced by banks in complying with sanctions ..

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14 May 2021

From Insights

Unpacking the EU Sanctions Blocking Regulation: Bank Melli v Telekom Deutschland

This week saw the first commentary from a member of the EU's highest Court on the EU Blocking Regulation since it was brought into renewed focus following the US withd..

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04 May 2021

From Insights

Sanctions: deceptive practices and high-risk areas – Part 2

In the second of our two-part series, we explore the common deceptive practices currently used by sanctions evaders in the maritime industry.

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12 Apr 2021

From Insights

Sanctions: deceptive practices and high-risk areas – Part 1

The maritime industry has transitioned to the front and centre of the global stage with increasing scrutiny on sanctions enforcement.

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16 Mar 2021

From Insights

UK sanctions post-Brexit March 2021

In this article we focus on UK sanctions post-Brexit.

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18 Dec 2020

From Insights

Webinar – Who’s afraid of sanctions? What will the international sanctions landscape look like in 2021?

On 8 December, Stephenson Harwood co-hosted a joint webinar with FTI Consulting. The webinar was moderated by Michael Imeson, senior content writer for the Financial T..

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25 Nov 2020

From Insights

US sanctions - who do they apply to and what steps can you take?

Following the US presidential election on 3 November, members of Stephenson Harwood’s sanctions team explore the scope of the US sanctions regime and its applicability..

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06 Apr 2020

From Insights

OFSI sharpens its teeth

As we explained in a previous briefing, in April 2017, the Office of Financial Sanctions Implementation (“OFSI”) was given powers to impose monetary penalties for brea..

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