What you might need to know about ...
International Sanctions
Over the last few years the introduction of international sanctions measures has seemed to grow exponentially. For anyone who is relatively, or completely, new to sanctions the landscape can be somewhat overwhelming.
successive iterations of
EU sanctions packages
The EU recently introduced the much heralded 14th package of 'restrictive measures' aimed at Russia, with additional measures issued related to Belarus. In the last two and a half years the UK, the US, and many other allies have issued a similar number of updates to their own sanctions measures.
Practitioners differentiate different types of sanctions measures including Financial, Trade, Immigration (travel bans), and Transport (restrictions on movement of aircraft and shipping). Most jurisdictions publish a certain amount of guidance on their webpages but of course to those less familiar with those jurisdictions and/or their webpages it can be difficult to find what is directly relevant to you.
In any case, as with many regulations, the good news is that a business only needs to get to grips with those parts of the legislation that affect its particular operations. The catch is how to determine which those parts are.
more sanctioned countries than you expect
Currently the UK has sanctions measures in place against more than 25 countries whilst for the EU it is more than 30 countries. Sanctions measures vary widely in terms of how extensive they are. The United States has 'comprehensive' sanctions in place against Iran, Syria, North Korea and Cuba. The global sanctions now in place against Russia and Belarus probably represent the most comprehensive ever in terms of sanctions that have been added to progressively over more than a decade.
Addressing relevant sanctions for your business first of all requires conducting an analysis of what applies based on where you actually do business. That analysis should include both where your supply chain is as well as where your markets are. Add into that any other partners you have elsewhere in the world and you start to have a basis from which you can evaluate what sanctions might be applicable. That should then reveal areas that are 'off limits' after which you have to think about what transactional screening procedures are appropriate for your business.
Together these two measures will provide a certain degree of comfort; from there the process can then be further refined based on individual circumstances and any planned changes in your operations.
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