Last week, the G7 foreign ministers met on the island of Capri in Italy, which is currently serving in the role of the G7 Presidency.  As one of the only law firms with offices and sanctions experts in every G7 country, we watched the meeting with great interest to see how the G7 will be approaching sanctions in the near future. 

We wanted to flag two quick takeaways from the statements coming out of the meetings:

  1. Keep an eye out for more sanctions targeting Iran across the G7 (and beyond). 

The ministers expressed support for more sanctions, referencing in particular Iran’s support for Russia and its April 13 missile and drone attack on Israel.  In fact, the US and UK have already introduced new sanctions and export control measures related to Iran’s drone and missile programs on April 19, which we will cover in more detail in a separate post.  Beyond the G7, the President of the EU has stated that the EU will back new measures targeting Iran. 

It will be particularly interesting to see how the ex-US measures develop given that the US has already had an embargo and extensive secondary sanctions for many years, while the G7 and others have always had much narrower restrictions.

  1. The G7 will remain focused on Russia sanctions enforcement and targeting parties that circumvent sanctions

It may come as no surprise that the G7 ministers expressed a focus on Russia sanctions enforcement.  Still, these statements underscore the need for companies to continue to approach sanctions compliance and investigations with the proper mindset and with an understanding that enforcement remains a priority. 

Our Global Sanctions Investigation Group recently launched a blog series to share what we have been seeing while acting on the first wave of sanctions investigations in the current hot enforcement environment – see the latest post here.

The G7 ministers also stated that they continued to be committed to preventing Russia sanctions’ circumvention by imposing additional sanctions on companies and individuals in third countries who help Russia acquire tools and other equipment for its military and industrial development. We have already been seeing this happening in recent sanctions actions.  Targeting parties in third countries (i.e., outside Russia) was previously rare or even unheard of outside the United States.  We expect to see more of this type of targeting.

The ministers also committed to continue immobilizing sovereign assets in G7 jurisdictions until Russia ceases its aggression, but they did not make statements about whether they would confiscate those assets to provide them to Ukraine for reconstruction, which has been an ongoing discussion.  The US House of Representatives passed a bill over the weekend that would give the President the authority to seize Russian assets that have been blocked under the US sanctions, and there has been a proposal in the EU to give the proceeds from the interest on the frozen assets to Ukraine rather than seize the assets themselves. 

Please subscribe to our blog and stay tuned for insights from our G7 experts on the ground in our Baker McKenzie trade teams in Italy, the US, Canada, France, Germany, Japan, and the UK as new sanctions developments unfold. 

Author

Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.

Author

Roberto Cursano focuses on healthcare law and compliance, and assists in tender procedures, the negotiation of public contracts and litigation before administrative courts. He is a former administrative officer in the Italian Ministry of Health and helps clients work closely with the Italian Public Administration. He is admitted to the bar before the Italian Supreme Court and the Council of State. Roberto advises primarily on pharmaceutical and healthcare matters. These include product licensing and marketing, clinical trials, pricing and reimbursement, promotions, interactions with healthcare professionals, distribution of products, and public procurement issues. Additionally, he assists in anti-bribery matters and related investigations, and helps set up internal compliance models preventing corruption-related crimes, money laundering and corporate crimes (so-called Law 231 Models). He also advises on administrative/public law, including export control law and public procurement law.

Author

Anahita heads Baker McKenzie's International Trade Practice in Germany and is a member of our EMEA Steering Committee for Compliance & Investigations. Anahita is Global Lead Sustainability Partner for our Industrials, Manufacturing and Transportation Industry Group and a member of the ABA International Human Rights Steering Committee. Anahita focuses her practice on global investigations and white-collar crime proceedings before German authorities and courts. She has significant experience advising on internal compliance programs, accompanying internal and external investigations and self-disclosures, inter alia in cases of breaches of sanctions, export control, human rights, data protection and foreign investment review, closely collaborating with the competent authorities.

Author

Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.