At the Annual Compliance conference recently held in London, Baker McKenzie hosted a session on ‘The evolving national security, sanctions and export controls landscape’. This session introduced the concept of the “trade toolbox” — a growing set of measures designed to manage national security risks through trade and investment restrictions. Speakers highlighted the increasing complexity of global compliance, particularly in relation to business relating to China, Russia, and in the Middle East.
China: outbound investment, export controls and data restrictions
The panel examined the increasing focus on outbound investment screening, export controls, and data transfer restrictions from a national security perspective. A key focus was the US Remote Access Security Act and its implications for cloud-based services and AI training models. The session also covered the US outbound investment regime and its potential expansion under a new administration, as well as the EU’s and UK’s parallel developments in FDI and export control regimes.
US data security rules: bulk data transfers and foreign access
Speakers discussed the US DOJ rule on preventing access to sensitive personal data by foreign adversaries. The rule, effective from 8 July, restricts access to data by entities linked to China, Russia, and others. Practical examples included shared service centres, cloud vendors, and global databases. The rule’s divergence from traditional data privacy and sanctions frameworks was also explored.
Russia: sanctions evolution and enforcement trends
This session addressed the latest US approach to Russia sanctions — including recent bills targeting energy and financial services. The UK’s Russia sanctions sectoral software restrictions and the EU Russia sanctions “best efforts” clause, and increasing focus on sanctions circumvention, were also discussed. Speakers emphasised the growing risk of secondary sanctions and the importance of due diligence in high-risk jurisdictions.
Middle East: sanctions, export controls and regional developments
The panel explored the UAE’s compliance framework and its alignment with international AML standards, as well as sanctions circumvention risks in the Middle East region. Developments in Syria were covered, including US general licences and EU/UK moves towards sanctions relaxation, with practical implications for businesses re-entering the Syrian market. The session also addressed continued focus on Iran sanctions, including SDN/DP designations, secondary sanctions targeting its energy and cyber sectors, and the expansion of internet-based services licensing. Regional tensions and anti-boycott enforcement were discussed, alongside the impact of political shifts on trade and investment.
You can access all materials from the Annual Compliance Conference 2025 here.