Sanctions law

The real strengths of this team are that they know their areas inside and out and go the extra mile to make sure clients are happy.

The Legal 500
Regulatory Compliance

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Sanctions regimes are complex and continually evolving in response to the geopolitical landscape. Businesses, particularly those operating globally, face considerable challenges in ensuring sanctions compliance given the threat of criminal and financial penalties amid potentially conflicting regimes. Frequently the issues that arise require urgent attention to avoid the risk of breaches while upholding commercial relationships and the day to day operations of a company.

Our team of specialist sanctions lawyers maintains strong working familiarity with all relevant sanctions legislation and is well-positioned to provide those companies affected with expert legal advice and support which is grounded in their corporate realities and objectives. It is critical for organisations to take proactive steps to protect themselves by ensuring their practices are compliant with sanctions regimes, thereby avoiding exposure to significant financial, political, regulatory and reputational risk. In light of an ever-changing situation, these practices must be kept under careful review.  

Sanctions regimes typically include both financial and trade measures, incorporating sanctions against individuals, companies, national bodies and sometimes even countries, as well as wider trade sanctions which target both specific goods and items (often identified by their commodity code) or wider categories of goods and items. While there may be limited exceptions to the sanctions, frequently the only way to continue dealing with a sanctioned individual, entity or item is to seek a licence from the relevant regulator.  

Our lawyers provide expert advice and assistance to individuals and businesses impacted by sanctions and deliver clear and comprehensive guidance in relation to the applicability of sanctions regimes and the options available to ensure compliance. We have extensive experience in advising clients in relation to specific transactions, interpreting relevant legislation and identifying areas of risk, dealing with regulators, and supporting on the implementation of compliance programmes. 

We have a dedicated global sanctions team for shipping, trade and energy supplying timely legal advice based on the practical aspects of how the industry operates and within the legal framework to mitigate potential risks. We advise across different cargo types such as oil and petroleum products, with a remit that includes trading/commodities brokering, financing, insurance, flagging, and customs brokering. Our energy lawyers, many of whom are multi-qualified, act for some of the biggest players from commodities traders, mining companies, contractors, operators and financiers to governments, oil companies, service providers and independent players.

We are also regularly involved in providing more generalist sanctions law advice, briefing clients on the jurisdictional scope and impact of different sanctions regimes and presenting a broader perspective on their legal and commercial implications. By offering practical and targeted guidance, we enable our clients to manage their risk more effectively, ultimately providing peace of mind as well as protection against sanctions-related litigation.  

Our sanctions lawyers have a strong global network of trusted partners, enabling us to coordinate complicated advice which spans multiple jurisdictions and provide around-the-clock, immediate support.  

We offer expert advice on:

  • sanctions analysis, interpretation and application
  • sanctions obligations for private individuals and companies
  • designing and implementing sanctions compliance guidelines and policies for companies
  • application of sanctions arising from orders placed by new or existing customers
  • licensing requirements, with a focus on the Office of Financial Sanctions Implementation
  • applying for new or varying existing licences from the Office of Financial Sanctions Implementation
  • dealing with regulatory authorities and coordinating the provision of advice in other jurisdictions while working with trusted partners
  • concerns regarding potential breaches of the sanctions regimes

Recent work highlights

Global sanctions policy

Preparing a sanctions policy for a multinational company in conjunction with US counsel to provide guidance to employees and ensure company-wide compliance.

Ban on oil products

Advising a multinational oil company on prohibitions on negotiating, buying and selling Russian oil, including consideration of the potential impact on both UK-based and other foreign subsidiaries.

Sanctions challenges in trade finance

Advising a Far East lender on the impact of Russian sanctions on repayments through an EU agent relating to international trade finance syndication, including OFSI and EU licence arrangements.

Disruption under the radar

Providing guidance to a client with facilities in Europe and Belarus on the UK and EU sanctions regimes against Belarus and their applicability to shipping Wi-Fi antenna between those facilities.

Related expertise

Penningtons Manches Cooper LLP

Penningtons Manches Cooper LLP is a limited liability partnership registered in England and Wales with registered number OC311575 and is authorised and regulated by the Solicitors Regulation Authority under number 419867.

Penningtons Manches Cooper LLP