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Economic and financial sanctions seek to prevent the targeted individuals or entities from dealing with their funds and accessing financial services, and are backed by civil and criminal penalties. Compliance is not always straightforward, particularly where different sanctions programmes collide and impose conflicting obligations.
Recent events in Ukraine have resulted in a number of new, significant and coordinated sanctions being imposed by the US, the UK, the EU and other jurisdictions. See Ukraine crisis section.
Even prior to the February / March 2022 imposition of sanctions, over the last ten years or so, sanctions have become an increasingly hot topic for the global financial markets: several banks have been subject to significant financial penalties for failure to comply with financial sanctions programmes and there have also been some recent high profile developments in relation to certain countries such as Iran and Ukraine (which have been in place since 2014 as a consequence of events in the Crimea). It is therefore vital for companies, especially financial institutions engaging in a multitude of different transactions every day, to monitor their compliance with sanctions, ensure that they are not in breach of the relevant sanctions legislation and take advice on how sanctions should be specifically addressed in transaction documentation.
Other important developments in the area of sanctions have included the amendment of the EU Blocking Regulation - see under Client briefings and presentations.
This Topic Guide has a limited selection of content on US sanctions, please contact our experts in Washington listed below for further information.
Carla Lewis (London)
Michael Lyons (London)
Dorothée Vermeiren (Brussels)
Torsten Syrbe (Dusseldorf)
Gerson Raiser (Frankfurt)
Dr. Heiner Hugger (Frankfurt)
Charles-Henri Boeringer (Paris)
Marcin Ciemiński (Warsaw)
David DiBari (Washington)
George Kleinfeld (Washington)
Jacqueline Landells (Washington)
John-Patrick Powers (Washington)
Renée Latour (Washington)
Philip Angeloff (Washington)
Lei Shi (Shanghai)
Janice Goh (Cabenagh Law, Singapore)
Kabir Singh (Singapore)
Nish Shetty (Singapore)
Tess Forge (Singapore)
Masafumi Shikakura (Tokyo)
Yuki Nakatori (Tokyo)
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Health warning: Below is a selection of client briefings produced by Clifford Chance offices, for a full list of our briefings please search on our website or contact one of our listed experts. Sanctions programmes are updated regularly and a client briefing is not necessarily prepared following each change. As a result, the client briefings below may not provide a complete picture of all the latest sanctions in the UK, EU and US. For an up to date list of the sanctions in force, please see the lists maintained by the applicable authorities listed under "External Resources" or contact one of our listed experts.
These new sanctions are complex, multilateral and continue to be incrementally changing in real time in response to the developments on the ground in Ukraine. Our team of sanctions experts is monitoring the situation closely and whilst we will endeavor to keep our briefings up to date, a client briefing is not necessarily prepared following each change.
We have a number of older briefings on the Russian and Ukrainian sanctions programmes, please search on our website or contact one of our listed experts if you would like to see these.
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