Sanctions are domestic and international political restrictions, targeting entities, individuals and governments, with the aim of preserving international peace and security. These may take the form of economic or trade sanctions, travel bans and asset freezes.
The United Nations Security Council, the US Office of Foreign Assets Control (OFAC), the EU and the UK's HM Treasury via its Office of Financial Sanctions Implementation all implement measures to impose arms embargoes, ban certain items or raw materials and prevent terrorist financing.
The UK adopts all UN and EU sanctions and certain entities and individuals in the UK may also be subject to OFAC sanctions. Export regulations control the export and trade of military and dual use goods and require a licence from the Export Control Organisation. Financial sanctions may apply to individuals, entities or governments who may be resident in the UK or abroad. Certain financial sanctions may also prohibit providing or performing other financial services, such as insurance, to designated individuals or governments.
It is a criminal offence to breach a sanction without the requisite licence or authorisation.
Our experience includes:
- representing a director in respect of a prosecution by HM Revenue & Customs for breaching trade sanctions
- advising a telecommunications company under investigation by HM Revenue & Customs for exporting controlled goods to Iran and implementing an export controls compliance policy
- drafting and implementing a global export controls compliance programme for a technology company
- advising companies and financial institutions on their compliance with international sanctions