Tristan Grimmer (UK), Author at Global Sanctions and Export Controls Blog

Sanctions on Iran Reinstated Following Triggering of JCPOA Snapback by E3

October 13, 2025 By Derk Christiaans (Netherlands), David Eriksson (Sweden), Tristan Grimmer (UK), Kaspar Projer (Switzerland) and Emily Thomson (UK) 9 Mins Read

On 28 August 2025, France, Germany, and the United Kingdom (the “E3”) formally triggered the “snapback” mechanism under the Joint Comprehensive Plan of Action (“JCPOA”), citing Iran’s continued non-compliance with its nuclear-related commitments. This move has been followed by weeks of unsuccessful negotiations at the United Nations aimed at extending the JCPOA framework. As a result of the snapback, and the failure to reach an agreement, all UN sanctions previously lifted under the JCPOA have…

UK Financial Sanctions Update: OFSI Imposes Monetary Penalty on Markom Management Limited

August 4, 2025 By Tristan Grimmer (UK), Kelvin Hong (UK) and Keir Burbidge (UK) 3 Mins Read

On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…

Webinar Summary – The rise and rise of sanctions investigations: lessons learned and future trends in the global era – Thursday 12 April

June 16, 2025 By Terence Gilroy (US), Tristan Grimmer (UK), Anahita Thoms (Germany), Sven Bates (UK) and Serez Gökçe (Turkey) 2 Mins Read

Sanctions enforcement is intensifying globally, with authorities expanding their toolkits and increasing cross-border cooperation. This session explored key developments in sanctions enforcement in the US, UK, EU and Turkey and the implications of these for the progression of civil and criminal investigations. This session first examined key developments in enforcement infrastructure and penalties frameworks across the different jurisdictions. This included the EU’s push for harmonisation, the UK’s new body for the enforcement of trade sanctions…

Webinar Summary – The Catch-22: Global strategies for navigating export controls, sanctions and countermeasures in China and Asia-Pac – Wednesday 4 June

June 13, 2025 By Tristan Grimmer (UK), Alison J. Stafford Powell (US), Frank Pan (China), Kana Itabashi 板橋加奈 (Japan), Louis Hsieh (Taiwan), Derk Christiaans (Netherlands) and Andrew Rose (UK) 1 Min Read

Geopolitical and geoeconomic tensions between China and the US remain high. This session explored the use of export control and other national security measures by competing regimes, drawing on perspectives from the US, China, the EU, the UK, Japan, and Taiwan. The session began with an overview of US national security policies towards China and recent efforts to regulate the flow of capital and data. This was followed by insights from China on retaliatory measures,…