Foreword

I am delighted to welcome you to this third edition of Global Investigations Review’s The Guide to Sanctions. The international, geographical, political, criminal, legal and regulatory elements that make up sanctions programmes ensure that this will remain one of the most complex compliance areas facing practitioners. The following chapters contain important information, advice and best practice for sanctions and export controls as a compliance discipline, courtesy of some of the world’s leading legal, forensic and compliance specialists. The daily change to the international regimes requires practitioners and businesses to be constantly monitoring and horizon-scanning across all relevant jurisdictions, and the Guide is packed full of resources that will enable readers to do just that.

The current sanctions environment makes this Guide a must read for any practitioner who manages or advises on sanctions compliance. This Guide is the work of leading industry specialists who have all given their time and expertise to produce a resource that should be on every bookshelf. At a time of growing complexity, readers may find the Guide worthy of being constantly consulted as a valuable reference resource, not only in its own right, but also for the treasure trove of links and references to information and guidance provided by the regulators who guide industry in implementing sanctions policy.

Sanctions never sleep, and since the previous version of this Guide, we have seen the UK settle into an autonomous programme and increased international coordination with major countries and blocs looking to align as closely as possible. The US is no longer the only major player.

The sanctions regimes in place for countries such as Iran, Syria, North Korea and Yemen, to name just a few, have continued to evolve, but the focus since August 2021 has been squarely on Russia and Belarus. This Guide will bring you up to date with the significant changes in those regimes, as at the time of writing, covering both the sanctions and export controls, as well as updating you on the developments in other regimes, including China and Hong Kong.

As with earlier editions, this third edition covers the major sanctions programmes from the United Nations, the United States, the European Union, the United Kingdom and the Asia-Pacific region, including the types of prohibitions imposed by the relevant programmes, the licence procedures and the measures that are available to challenge listings. Each of the major jurisdictions has an enforcement section that details the process and elements of enforcement from the relevant jurisdiction. The Guide also covers the re-emergence of thematic sanctions programmes; no longer limited to terrorism and narcotics, these programmes have seen a significant growth over the past few years. The third edition welcomes new authors who share their experiences representing sanctioned clients, among others.

The section on compliance programmes will enable readers to review their own programmes against best practice and improve and enhance their own controls if required. The final section covers sanctions and export controls in practice, giving good advice on how to navigate international, extraterritorial and often conflicting requirements of global sanctions and export control rules.

It is important to remember that financial crime is not a competition and that we make the biggest impact when we work together across industry and governments. The partnerships and collaboration across the globe play an important part in managing international sanctions. Part of my role at UK Finance is to liaise with industry and governments to help promote public–private partnerships and ensure that we are all fighting financial crime, especially in the sanctions space, as a coordinated and collaborative network of specialists, in the UK and elsewhere.

The Guide to Sanctions is intended to enable readers to be a valuable part of the sanctions and export controls community, dedicated to fighting financial crime and helping to protect our wider society from the impacts of those that seek to cause harm on the international stage.

Neil Whiley
Director of Sanctions, UK Finance
June 2022

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