Sanctions and Export Controls

Peters & Peters are recognised experts in the field of financial sanctions and export controls, capable of addressing complex multi-jurisdictional matters and the legal, commercial and public policy dynamics at play in this area. World ECR named our team Sanctions Law Firm of the Year (Europe) in 2015.

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Sanctions can target governments, entities or individuals. They can impose prohibitions and restrictions on trade, financial transactions and travel as well as broad-ranging asset freezes. Export controls impose additional restraints on trade in specified ‘dual use’ goods and technologies capable of having a military use and on other items where there is a concern about end use (e.g. for military or nuclear proliferation purposes).

The UK regime is comprised of a mix of legislation implementing sanctions and export controls imposed by the UN and the EU as well as unilateral UK sanctions. Breaches may amount to a criminal offence punishable by up to ten years’ imprisonment and/or an unlimited fine. As of April 2017, the Office of Financial Sanctions Implementation (OFSI) has the power to levy civil monetary penalties for financial sanctions breaches of up to £1m or, if higher, 50% of the estimated value of the breach.

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

The same conduct may engage more than one form of restriction, and more than one regime. We work in close cooperation with partner firms in the relevant jurisdictions to deliver tailored compliance advice for multi-jurisdictional operations, and can advise you on the extraterritorial application and enforcement of overseas sanctions law and export controls.

Our firm’s approach is notable in that we are able to draw, when providing compliance advice, on our considerable experience in sanctions- and export control-related litigation. Peters & Peters has represented a significant number of persons who have been designated as targets of financial sanctions, including high-profile individuals, commercial entities across a variety of sectors (including financial services) and governments. We advise on filing administrative challenges against EU and UK designations, and on applications for the annulment of EU legislation as well as sanctions-related judicial review applications. We brought the first judicial review of how the UK implements EU financial sanctions, as well as the largest sanctions challenge filed at the General Court of the EU in respect of 123 Zimbabwean nationals/entities.

We have long experience in dealing with the relevant licensing authorities in the UK and overseas, and regularly liaise with financial institutions in this connection. We specialise in advising businesses affected by sanctions and exports controls on the licences they need to continue or resume commercial operations in compliance with applicable regimes, which may include the submission of relevant licence applications on their behalf. This work often involves us dealing with a range of government agencies and regulators, in the UK as well as overseas.

Key Contacts

Michael O'Kane

Michael O'Kane, Head of Business Crime

Email Michael

+44 (0)20 7822 7755

Hannah Laming

Hannah Laming, Partner

Email Hannah

+44 (0)20 7822 7752

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