Sanctions target a wide range of governments, entities or individuals. They can prohibit and restrict commercial and private activities alike. Export controls impose additional prohibitions and restraints on strategic trade including military and ‘dual use’ goods, items and technologies.

The UK’s autonomous regime comprises a mix of primary and secondary legislation – including the Sanctions and Anti-Money Laundering Act as well as the Export Control Act – implementing sanctions and export controls imposed by the UN or by international agreements, as well as unilateral or ‘autonomous’ UK sanctions. Persons involved in violations may be exposed to terms of imprisonment of up to seven years (for financial sanctions breaches) and ten years (for trade sanctions and export control violations) and/or unlimited criminal fines. The Office of Financial Sanctions Implementation (OFSI) has the power to levy civil monetary penalties of up to £1m or, if higher, 50% of the estimated value of the breach.

We are well positioned to advise you on what prohibitions and restrictions may apply to you, and what your obligations are in the event that you discover an actual or potential breach.

The same conduct often engages more than one country’s regime and we work in close cooperation with advisers around the world on internal investigations and external enforcement actions, as well as to deliver tailored compliance advice for businesses.

Our advice and representation also draws on our very wide experience in challenging sanctions designations.

We represent individuals and entities designated as targets of financial and trade sanctions, operating across a broad range of commercial sectors and industries, including governments.

We advise on the preparation and submission of administrative and legal challenges to designations, as well as on judicial review applications concerning related decisions.

We brought the first judicial review of how the UK implemented EU financial sanctions, as well as the largest sanctions-related annulment application ever filed at the General Court of the EU in respect of 123 Zimbabwean nationals and entities.

We have long experience of dealing with the licensing authorities in the UK and overseas, and regularly liaise with financial institutions in this connection. We specialise in advising on the licences businesses need to continue or resume commercial operations in compliance with applicable sanctions and export control regimes, including assistance with the submission of relevant licence applications on their behalf. This work often involves us dealing with a range of authorities and other interested parties, in the UK as well as overseas.