As risks and complexities for sanctions investigations have grown, so has the number of regulators and enforcement agencies bringing enforcement actions, and not just in the United States. Enforcement agencies around the world are becoming more active, with a focus on enforcing sanctions and export controls targeting Russia since its February 2022 invasion of Ukraine. There has been a particular uptick in public enforcement of EU sanctions targeting Russia by various EU Member States in…

In the high-stakes world of sanctions investigations, where data privacy meets sanctions regimes, companies and practitioners must navigate both domestic and international legislation while ensuring compliance with regulatory agencies. In the complex landscape of sanctions investigations and the need to identify and collate documents that are relevant to the investigation, data protection plays a crucial role. The initial phase of a sanctions investigation often involves fact finding in order to establish the complete picture of…

Companies caught in the eye of the sanctions enforcement storm can only begin to effectively weather it by conducting a thorough internal investigation. These investigations are multifaceted (see our other blog posts in this series here), but an essential component is often conducting interviews. Interviews are a fundamental part of cross-border sanctions investigations that combine practical and legal challenges. Organizing them effectively requires an appreciation of practices in different jurisdictions, including local laws, customs, and…