On 11 June 2024, the UK Court of Appeal handed down its judgment in the case of Celestial Aviation Services Limited v UniCredit Bank GmbH (London Branch) [2024] EWCA Civ 628. In summary, the Court of Appeal determined that, in the context of payment obligations under standby letters of credit (“LCs”), sanctions measures relating to financing the supply of restricted items can apply retrospectively as well as prospectively, significantly widening the scope of application of…
In the midst of ongoing sanctions investigations and enforcement actions, companies are faced with yet another challenge: interested third-party stakeholders. Companies must decide who to share information with, what levels and types of information to share, how to share information, and how to mitigate the risks of loss of legal privilege, leaks, and triggering disclosure/reporting obligations by others. In this blog post, the Global Sanctions Investigations Group focuses on three critical third party stakeholders –…
For the second week of our Annual Compliance Conference, we discussed key trade compliance issues impacting our clients globally. Specifically, we discussed the trade policy response of the US, EU and U.K. to ever increasing geopolitical disruption, global strategies for handling sanctions regulators and enforcement, and key global sanctions and export controls developments. Trade policy response to geopolitical disruption – China and beyond Tuesday 7 May SPEAKERS: Tristan Grimmer (Partner, London), Sylwia Lis (Partner, Washington…
A company’s Russia-bound shipment gets stopped by customs authorities in the UK, which claim the products are prohibited for export to Russia. After confirming that the products are indeed restricted, the company initiates an internal investigation to get to the root cause of the problem and remediate. A whistleblower uses its employer’s compliance hotline to report concerns about possible US, EU, and UK sanctions or export controls violations. The company initiates an internal investigation to…