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^{Conquer Complexity: How to Navigate Risk and Select a Sanctions Law Firm}

In today’s fluid regulatory environment, general counsel increasingly turn to specialist advisors to protect their sanctions compliance.

Ali Mirjani-Arjenan — Principal Research Specialist (Sanctions and International Trade), Chambers

Sanctions law has shifted from a niche concern to a strategic must-have.

Since 2022, restrictions have increased rapidly, chiefly in response to Russia’s invasion of Ukraine.

What’s more, differing applications by different regimes make it tricky to stay compliant while doing business effectively.

Russia: A Unique Challenge

Since 2022 there has been a 311% increase in measures targeting Russia. Unlike other sanctioned states such as North Korea or Iran, Russian entities had deep ties to global supply chains, investment portfolios, and corporate contracts. From energy contracts to real estate holdings, the challenge wasn’t just legal—it was structural.

The package of new restrictions put in place covered both major areas of sanctions compliance law, against the regime and against individual entities and actors (designation and delisting).

This article focuses on regime-wide restrictions, which are the main component of sanctions risk management for the majority of in-house teams.

Russia was deeply integrated into Western financial and commercial systems. Unwinding these relationships was far more complex.

The invasion triggered a wave of new sanctions regimes, often developed rapidly and without precedent.

GCs now need to be far more proactive and strategic.”

To explore sanctions across jurisdictions, visit our Sanctions 2025 Global Practice Guide.

Navigating Different Jurisdictions

One of the most challenging aspects of sanctions compliance is the divergence between regimes.

While the US, UK and EU often align on high-level targets, enforcement models and risk thresholds differ in ways that can expose even cautious companies to liability.

The US, via OFAC, applies strict liability and aggressively enforces secondary sanctions—even against non-US entities. Export controls and licensing requirements add further complexity, especially for US-origin goods and dollar-denominated transactions.

The UK, through OFSI, also applies strict liability but focuses on administrative enforcement. Companies must show they’ve taken “reasonable measures” to prevent breaches. Licensing is required for certain transactions, though turnaround times and scope differ from OFAC.

The EU takes a more formalist approach. While it avoids extraterritoriality, it imposes best-efforts obligations on EU-linked entities. Enforcement varies by state, and asset freezes hinge on ownership and control tests.

“The shifting rules can make it feel like treading water the entire time. You need people who are abreast of competing developments in different jurisdictions—and have the ability to disentangle from agreements which have become politically tenuous.”

Read the rest of this in-depth feature on Chambers.com to discover:

A New Approach to Sanctions Management
What GCs Should Look for in a Sanctions Law Firm

Read full article