Sanctions

Sanctions

The UK left the EU on 31 January 2020. A transition period, during which EU laws continue to apply in the UK, is due to end on 31 December 2020. The UK/EU Withdrawal Agreement sets out transitional arrangements and negotiations for the future UK/EU relationship are ongoing.

The sanctions landscape is constantly changing. Navigating its interconnected global complexities requires expert advice.

Wide-reaching prohibitions, trade restrictions and export controls imposed by the United Nations, European Union and the UK Government can affect any business’s activities and the consequences of falling foul of these prohibitions can be severe. Breaches of sanctions, including circumventing any restrictive measures, can lead to criminal penalties and large fines, and punitive measures are only being broadened. For instance, the UK Treasury's Office for Financial Sanctions Implementation (OFSI) can now impose civil as well as criminal penalties. These require a lower burden of proof, with a maximum fine of up to £1 million or 50% of the value of the offence. In addition, breaches of criminal sanctions can now be dealt via deferred prosecution agreements for corporate entities.

Furthermore, in England and Wales the responsibility for reporting offences has been expanded to a far wider group of professionals including among others, auditors, estate agents, tax advisors and lawyers. Failure to do so is itself a criminal offence, whether that is reporting an actual offender or simply a “designated person” in a failing ‘regime’.

To meet this regulatory challenge our sanctions experts sit within a team of almost 200 litigators and include former senior members of the Crown Prosecution Service. Though we are based in London, we have access to the best local specialist law firms around the world through our networks and relationships. We are not part of a large global firm obliged to use a local office.

We have represented both individuals and organisations that have fallen foul of sanctions agencies around the world. We rescued a US law firm caught up in the Volcker investigation into oil for food and a sovereign wealth fund subject to Treasury and US sanctions. We know how to deal with HMT/OFSI on notifications, licence applications and submissions that relate to sanctions violations issues. When necessary our sanctions lawyers can turn to our colleagues in Reputation Protection, their expertise, and the latest electronic disclosure and case management tools.

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