Sanctions and international trade

Our team has deep expertise in UN, EU, U.S., U.K., and other sanctions and export control regimes; international trade law and policy (including WTO rules); trade and customs disputes; and foreign investment and national security-related issues. Our team advises across all sectors and in all contexts (both contentious and non-contentious), and across the business cycle. We can provide risk assessments and due diligence services to ensure the sanctions and export control-related compliance of any particular structure, joint venture, or contractual relationship. Where export control licenses are required, we can help ensure that these are appropriately put in place.

Our team further works hand-in-hand with our corporate and M&A, finance, and capital markets lawyers on both M&A deals and banking, project finance, and capital markets transactions. In this context, we advise our clients on how any identified sanctions and export control-related risks arising from such transactions can be de-risked through the use of contractual protections, operational and compliance protocols, and the use of licenses, including in scenarios where counterparties are, or are dealing with, persons targeted with sanctions or operating in sanctioned countries (including Russia).

Multijurisdictional advice and training

We provide cross-border guidance on how to manage conflicting or overlapping sanctions obligations and blocking laws across multiple jurisdictions, and help our clients mitigate risk through drafting and implementing sanctions compliance policies and training programs for senior management, boards, employees, and agents.

Team members with agency and contentious experience

Members of our team have worked for agencies including the U.S. Office of Foreign Assets Control (OFAC), the European Commission, and the Committee on Foreign Investment in the United States (CFIUS), giving us an insider's perspective on how these authorities operate and what they expect from businesses. 

In addition, our litigators—many of whom are former government prosecutors—provide top-tier support to defend our clients in investigations and prosecutions relating to sanctions and other regulatory breaches in the U.S., U.K., EU, the Middle East, and Asia-Pacific.

Representative matters 

• Advising clients on their withdrawal from the Russian market in light of international sanctions and/or the ringfencing of their Russian businesses.
• Assisting clients to undertake investigations—and to engage in litigation or dispute-related proceedings—connected to international sanctions regimes and export control laws.
• Facilitating the development of clients’ sanctions and export control policies and procedures, their monitoring and review, and the provision of trainings on the same, as well as sanctions issues more generally.
• Providing bespoke advice on technical questions, including through the conducting of cross-jurisdictional assessments and risk analyses, and the applicability of blocking laws.
• Helping clients understand and categorize dual-use items, military goods, and end-use and end-user restrictions, as well as the use of associated licenses (including OGELS, OGTCLs, SIELS, and OIELS).
• Assisting with the development and submission of sanctions and export control license applications, and strategies for otherwise dealing with questions from key regulatory authorities.

• Aiding numerous financial institutions and corporates to address sanctions and export control-related issues, including via the undertaking of due diligence and negotiation of contractual protections.
• Advising major aerospace and defense companies on various aspects of EU and U.S. export controls and trade sanctions, including in relation to dual-use items, military goods, and end-use and end-user restrictions.
• Assisting an international oil and gas major in relation to EU/U.S. sanctions litigation and investigations involving one of its Asian subsidiaries.
• Aiding the Republic of Cuba in its challenge to Australia's Tobacco Plain Packaging Act 2011—the first time that Cuba has challenged another country's commercial legislation at the WTO.
• Assisting a global financial institution in relation to a criminal investigation conducted by the Belgian authorities into the alleged handling of Libyan assets in breach of UN, EU, and U.S. sanctions rules against Libya.
• Helping numerous clients across a full range of sanctions compliance matters concerning jurisdictions such as Russia, Iran, Venezuela, Cuba, Sudan, and Egypt.