Global Investigations Review - The law and practice of international investigations

GIR launches the Guide to Sanctions

18 September 2020

GIR launches the Guide to Sanctions

GIR has published its first edition of the Guide to Sanctions – an overview of regimes across the globe and tips on how to navigate them, featuring insight from former government officials and market-leading practitioners in the US, EU and Asia.

The e-book version of the guide can be downloaded for free while hard copies are available to subscribers or for purchase.   

“For newcomers, it will provide an accessible introduction to the territory. For experienced practitioners, it will help them stress-test their own approach. And for those charged with running compliance programmes, it will help them do so better. Whoever you are, we are confident you will learn something new,” said GIR’s publisher David Samuels.

The guide features a foreword by Sigal Mandelker, the former under secretary of the Treasury for terrorism and financial intelligence, and contains 17 chapters addressing issues ranging from dealing with US authorities to sanctions and export controls in the Asia-Pacific region and also EU and UN sanctions regimes. 

The guide’s editors are London-based Rachel Barnes at Three Raymond Buildings, Anna Bradshaw at Peters & Peters, Paul Feldberg at Jenner & Block, as well as David Mortlock at Willkie Farr & Gallagher in Washington, DC, Anahita Thoms at Baker McKenzie in Düsseldorf and Nicholas Turner at Steptoe & Johnson in Hong Kong. 

“There are books on anti-money laundering, there are books on bribery and corruption but there’s nothing like this for sanctions,” said Feldberg. “Sanctions is one of those areas that’s a complete mystery to some people and it doesn’t have to be.”

Sanctions enforcement and compliance is a section of the law that has historically been difficult for lawyers to get a handle on research alone. “There’s almost an oral history, an unwritten culture and there are a small number of initiated people who have learned by doing – and that doesn’t always get written down.”

“The idea of the guide was to take the collective knowledge of each practitioner and create a guide that looks at the issue from as many perspectives as possible, from regional or by subject matter expertise,” he added. 

The guide was created with a global mindset to mirror the challenges that practitioners – be they lawyers, in-house compliance staff or forensic investigators – face. “The guide is the first – at least as far as I’m aware – that covers not only a broad range of trade issues but also a broad range of regions,” said Thoms.

“We looked at various regions that are of primary concern to globally acting companies and it was important to us to give practical examples in all of our chapters drawing from a practitioners perspective,” she added.

Bradshaw said: “The book that you have now is the best you can get. While it doesn’t profess to give an exhaustive account of everything you need to know to practice sanctions law or give advice, it should give you enough of the broad flavour of the complexities and where to go for more information when you need to.”

The book’s publication comes almost a year after GIR launched Just Sanctions, a specialist section of the website focused on high-stakes sanctions investigations and enforcement. Follow GIR’s coverage by subscribing to the free Just Sanctions newsletter.

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