For several years, the EU has increasingly used economic sanctions against third countries such as Iran, Syria, Ivory Coast or Belarus as a foreign policy tool. The EU does not merely implement the UN sanctions but imposes autonomous sanctions, targeting specific persons, industries, or products. The sanctions apply to all companies with operations in the EU, and failure to comply with the sanctions can result in heavy fines and reputational damage for companies, and imprisonment for the individuals involved.
Navigating EU sanctions and export control regimes is complicated and full of pitfalls. The sanctions use many broad and undefined concepts, there is little official guidance on the interpretation of these concepts, and precedents are rare. Moreover, enforcement is decentralized and is in the hands of the 28 Member States, some of which have even delegated it to regional authorities.
We have considerable experience in advising clients on all aspects of the operation of the economic sanctions imposed by the EU, as well as EU and national export control laws. Our lawyers in Europe and the U.S. provide seamless advice on EU and U.S. issues. Where necessary, the team also coordinates advice on sanction regimes imposed by other jurisdictions such as Canada, China or Australia. Our experience covers the full range of issues that arise in the context of EU economic sanctions and export controls:
- Advising clients on the permissibility of specific transactions or payments
- Conducting trade compliance audits, risk assessments, and due diligence
- Developing trade compliance manuals and providing trade compliance training
- Representing clients in investigations before national authorities and courts