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 (OTSI), and the US focus on companies engaged in diversion activities. The panel also discussed key takeaways from the first phrase of Russia investigations and other recent enforcement cases. This involved commentary on the uptick in US-UK co-operation, increased intra-EU information sharing, and the impact of Western sanctions on Turkish business practice.
We also looked to the future of sanctions related enforcement, including how the Trump Presidency may impact US enforcement in relation to Russia and China, and how prospective amendments to the US Syria sanctions regime may impact investment in that market from US and Turkish companies. In relation to the UK, the panel also discussed the likelihood of increased regulator emphasis on circumvention activities and identifying novel cases.
Our speakers concluded with the key implications of these developments for clients. This discussion covered the importance of ensuring that sanctions are a priority for any compliance function, and the importance of stress-testing business exposure to high risk regions such as Russia, China and the Middle East. Businesses may also consider careful management of relationships with key external stakeholders, including auditors, banks, regulators and the press, as expanded information flows and reporting obligations drive further gateways for investigations.
You can access the webinar recording here.
