Sanctions

We have a thriving economic sanctions practice advising corporations, financial institutions, and individuals on economic sanctions administered or enforced by the United States, the European Union, the United Nations and many other jurisdictions.  The core of the practice involves advising on U.S. programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the U.S. Department of State, as well as divestment legislation in force in approximately 30 U.S. states.  We have particular experience advising on OFAC Sanctions and related Executive Orders, the Iran Sanctions Act (as amended by CISADA and other laws) and a variety of other Iran-related sanctions, the Trading with the Enemy Act, the International Emergency Economic Powers Act and other similar statutes and Executive Orders designed to restrict business dealings with sanctioned countries, persons or entities.

We also have extensive experience advising on U.S. foreign ownership restrictions, including in particular in connection with contemplated transactions that may impact U.S. national security.  We routinely assist clients in their dealings with The Committee on Foreign Investment in the United States (CFIUS).  We have advised on transactions involving prospective acquirers from all over the world (including China, India and other parts of Asia, Australia, the Middle East, Europe, Canada and Brazil), and a broad range of industry sectors (including telecommunications, consumer electronics, mining, defense, aerospace, energy and infrastructure). 

As a complement to our sanctions practice, we offer strong anti-money laundering and counter terrorist financing expertise.  Our experience includes advising on the Bank Secrecy Act, as amended, including by Title III of the USA PATRIOT Act, U.S. federal criminal money laundering provisions, state money laundering laws, and Financial Action Task Force (FATF) and other international guidance.  We have colleagues around the globe, who can advise on the European Union Money Laundering Directives and the rules and regulations in numerous jurisdictions. 

We have what we believe to be the leading global sanctions team, which provides integrated cross-jurisdictional advice to our clients, assisting them in navigating the complex and sometimes competing requirements to which they, or their investors, lenders, advisors or partners, may be subject.  We believe that our ability to provide not only top-level U.S. advice but also integrated cross-jurisdictional advice on international economic sanctions is unmatched by any of our peer firms.  

You can find more information about the Sanctions practice area on the main Allen & Overy website.