Sanctions and Export Controls

The imposition of sanctions by the United Nations and the European Union is a powerful weapon used on the international stage against regimes and individuals deemed politically unacceptable. Financial sanctions can prevent the provision of direct or indirect economic benefit to a host of entities, whereas trade sanctions inhibit the provision of goods or services.

Such measures can often place companies, financial institutions, advisors and targeted individuals  in very difficult situations, almost always running in tandem with other national and international legal instruments such as money laundering regulations, extradition and mutual legal assistance. Rarely will a client require advice about the sanctions regime in the absence of other such considerations.

Peters & Peters has years of experience of providing practical and high level advice in such complex situations.  Our experience at dealing with mutual legal assistance, money laundering, restraint, confiscation, extradition and Interpol places us at a distinct advantage in being able to provide a comprehensive client service. 

Highlight Cases

We currently represent a significant number of Middle Eastern individuals facing sanctions and other financial orders as a result of regime change. In particular, we act on behalf of Ahmed El-Maghraby, the former Housing Minister of Egypt, and his wife, in respect of a challenge lodged in the EU General Court against the validity of the current EU Sanctions. 

We have also been instructed by a number of current members of the government of an African state that is subject to wide-ranging EU and UK Sanctions. The matter is at an early stage, but will also involve a challenge in the EU General Court.

We act for an individual  in relation to an HMRC investigation into the alleged exportation of ‘dual use’ goods, without the requisite licence. The case involves complex technical questions regarding the scope of the dual use prohibitions under EC and domestic law. 

We are currently advising an Iranian businessman on an appeal against a conviction for breaching sanctions law.

We act for a multi-national company advising them on UK and EU sanctions relating to the export of goods to  Iran and related financial sanctions. This case requires advice on the difficult position where contracts are frustrated as a result of the imposition of sanctions, and consideration of relevant contractual, civil, and licensing obligations, involving HMRC, BIS and the Asset Freezing unit of HM Treasury. 

We act for a  maritime company that is  the subject of an investigation by the United Nations Monitoring Group into alleged breaches of the UN arms embargo against Somalia. 

We continue to advise a number of companies and individuals allegedly involved in the corrupt UN “Oil for Food” Programme to Iraq.

We advised two senior employees of a major UK bank that was investigated in the US for breaches of US sanctions law. The investigation was conducted by the US Treasury Department, the Department of Justice and state prosecutors and, for our clients, it related only to their conduct in the UK. The bank reached a settlement with the US Government which resulted in a deferred prosecution agreement and forfeiture of $350 million.

Our work has also included inquiries into the importation and sale of endangered species' skins/furs. This is a developing area of law, with new CITEs regulations passed in the UK.