The winds of change continue to swirl in the world of international sanctions enforcement.  Governments around the globe are imposing new sanctions at a rapid pace and ramping up their efforts to crack down on violations.

At Baker McKenzie, the Global Sanctions Investigations Group understands that navigating the ever-evolving sanctions landscape can feel like walking a tightrope.  One misstep and your company could be facing material fines, reputational damage, and even criminal charges.

That’s why we have launched our new blog series: Navigating the Impending Global Sanctions Enforcement Storm.  Why a storm, you ask?  Because a perfect storm is brewing: increasingly complex regulations, heightened enforcement activity by an increasing number of enforcement agencies, and the ever-growing web of often-interlapping and sometimes-conflicting international trade regulation.  Companies of all sizes are potentially at risk.

Over the coming weeks and months, we’ll be diving deep into sanctions investigations with our stellar global team of international trade and government enforcement experts.  We’ll be showcasing the diverse experience and knowledge of our lawyers from across the globe, including their insights from representing clients in global sanctions investigations and enforcement actions.

Baker McKenzie’s Global Sanctions Investigations Group is the leading global practice, acting on the first wave of sanctions investigations arising from the Russia-Ukraine crisis in the United States, UK, and EU.  Our global presence and expertise is critical in an age of greater international coordination among countries in the area of enforcement.  This series will build on last year’s series on this blog, “Sanctions Enforcement Around the G7” and “Sanctions Enforcement Around the World,” recapped here.

Certainly, active dockets of sanctions investigations in the United States are nothing new and did not begin with the Russia-Ukraine crisis.  The Department of Justice, Office of Foreign Assets Controls, Bureau of Industry and Security, and others have long been active in pursuing criminal and civil enforcement cases.  Even so, these agencies have made clear that they are newly focused on vigorous enforcement of various sanctions and export controls, as a complement to the multitude of new restrictions and prohibitions that have been implemented in recent years.

At the same time, a narrow focus on US enforcement risk is no longer sufficient.  Given the high stakes, many countries allied with the United States are ramping up their own enforcement efforts, both in terms building internal capabilities and increasing international cooperation.  In the UK, this has manifested itself in the introduction of new enforcement powers, overhauling of enforcement agency resourcing, and a shift to an intelligence led enforcement model, supported through close cooperation with the United States and others.  The EU has seen the emergence of the first enforcement cases – including in Germany and the Netherlands – underpinned by a recognition that without enforcement the sanctions measures will not achieve their objective.

As a result, companies concerned about potential sanctions investigations or facing ongoing sanctions investigations need to ensure they are considering the best approaches from a multi-jurisdictional perspective.  There is no one better placed than Baker McKenzie’s Global Sanctions Investigation Group to provide companies with practical insights from their experiences with cross-border and complex sanctions investigations. 

Here’s a taste of what you can expect:

Insights from the Front Lines: Our colleagues will share real-world case studies and practical tips on how to mitigate sanctions risk and navigate investigations with confidence.

Demystifying the Maze: We’ll break down complex sanctions regulations and enforcement trends into clear, actionable information you can use to protect your business.

Global View, Local Expertise: Our team spans the globe, so you’ll get insights into the unique challenges and enforcement priorities and how they differ across regions.

In our next post, we’ll be delving into some of the things that could trigger an international sanctions investigation for your company.  Stay tuned for these insights and more in the coming weeks.  

View all posts in the “Navigating the Impending Global Sanctions Enforcement Storm” series.


Jess is a technology investigations partner practicing at the forefront of government enforcement in the technology industry. Jess leads Baker McKenzie's investigations and compliance practice on the West Coast. For more than two decades, Jess has defended companies and individuals in government investigations and conducted internal investigations involving cutting-edge technology issues including AI, cybersecurity, and alleged misuse of all kinds of data. Jess has defended companies and individuals across the Asia Pacific region since the first DOJ Antitrust cartel investigations in 2003, and has a deep understanding of cultural issues impacting investigations in that region and across the globe. Jess has been recognized by Chambers & Partners, The Legal 500, and Global Investigations Review for internal investigations and defense in cases involving White Collar Crime & Government Investigations.


Tristan Grimmer is a partner in Baker McKenzie's London office and the UK Head of the International Trade Practice Group. He is also a member of the Compliance & Investigations and the International Trade and Competition practice groups. Tristan joined Baker McKenzie as a trainee in March 2004, qualifying in March 2006. He has advised on parallel investigations by authorities in the United States, Switzerland, Brazil and Japan, and has spent time working in Baker McKenzie's Chicago office. Tristan is named as a "Leading Individual" for EU And Competition: Trade, WTO Anti-Dumping and Customs in the UK Legal 500 2023 directory.


Alex advises clients on compliance with US export controls, trade and economic sanctions, export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and antiboycott controls. He counsels on and prepares filings to submit to the US Government's Committee on Foreign Investment in the United States (CFIUS) with respect to the acquisition of US enterprises by non-US interests. Moreover, Alex advises US and non-US companies in the context of licensing, enforcement actions, internal investigations, compliance audits, mergers and acquisitions and other cross-border transactions, and the design, implementation, and administration of compliance programs. He has negotiated enforcement settlements related to both US sanctions and the EAR.