In an era where regulatory compliance is under intense scrutiny, the importance of a well-orchestrated response to trade and sanctions investigations cannot be overstated. An investigation may involve transactions occurring in multiple jurisdictions, laws of separate jurisdictions, and inquiries from (or disclosures to) multiple governmental authorities. Investigations may begin through an internal whistleblower or other internal discovery, which grants the company more discretion in directing the tempo and scope of the investigation. In other instances,…
The leader of Russia’s political opposition, Alexei Navalny, died in a Siberian prison on February 16, just over a week before the two-year anniversary of Russia’s full-scale invasion of Ukraine on February 24. Both Navalny’s death and the anniversary of the invasion were cited as the motivations behind the latest rounds of sanctions against Russia. Members of our global sanctions team in our offices in the US, UK, Sweden, Australia, and Canada summarize the latest…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Sweden, an EU member state that is currently seeing increased sanctions enforcement activity. What are the recent sanctions enforcement trends in Sweden? In Sweden, but also in the Nordic region, the enforcement of sanctions violations has historically been rather low with a handful of criminal enforcement cases. However, during the past 12 months enforcement has been increased significantly, including…
The G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefit of G7 economies” on the one-year anniversary of Russia’s invasion of Ukraine. The International Group of Seven (“G7”) is an intergovernmental forum whose members include the US, UK, Germany, France, Italy, Canada, and Japan, with the European Union as a “non-enumerated” member. As such, Germany, France and Italy are EU Member…