{"id":27100,"date":"2025-10-09T13:27:02","date_gmt":"2025-10-09T12:27:02","guid":{"rendered":"https:\/\/wpcms.chambers.com\/?post_type=topics&p=27100"},"modified":"2026-02-04T16:11:07","modified_gmt":"2026-02-04T16:11:07","slug":"conquer-complexity-how-to-navigate-risk-and-select-a-sanctions-law-firm","status":"publish","type":"topics","link":"https:\/\/wpcms.chambers.com\/topics\/conquer-complexity-how-to-navigate-risk-and-select-a-sanctions-law-firm\/","title":{"rendered":"Conquer complexity: how to navigate risk and select a sanctions law firm"},"content":{"rendered":"\n

In today\u2019s fluid regulatory environment, general counsel (GCs) increasingly turn to specialist advisors to protect their sanctions compliance. <\/p>\n\n\n\n\n\n

Sanctions law has shifted from a niche concern to a strategic must-have. Since 2022, restrictions have increased rapidly, chiefly in response to Russia\u2019s invasion of Ukraine. What\u2019s more, differing applications by different regimes make it tricky to stay compliant while doing business effectively. Here we explore the vital issues and how in-house legal should assess a sanctions law firm with Ali Mirjani-Arjenan, Principal Research Specialist (Sanctions and International Trade) at Chambers and Partners.<\/strong><\/p>\n\n\n\n\n\n

Since 2022 there has been a 311% increase<\/a> 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\u2019t just legal\u2014it was structural. <\/p>\n\n\n\n\n\n

Ali Mirjani-Arjenan, Principal Research Specialist (Sanctions and International Trade), Chambers and Partners<\/em><\/p>\n\n\n\n

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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). <\/p>\n\n\n\n

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

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 such as Russia, their enforcement models and risk thresholds differ in ways that can expose even cautious companies to liability.  <\/p>\n\n\n\n

The US<\/a>, via OFAC, applies strict liability and aggressively enforces secondary sanctions\u2014even against non-US entities. Export controls and licensing requirements add further complexity, especially for US-origin goods and dollar-denominated transactions.  <\/p>\n\n\n\n

The UK<\/a>, through OFSI, also applies strict liability but focuses on administrative enforcement. Companies must show they\u2019ve taken \u201creasonable measures\u201d to prevent breaches. Licensing is required for certain transactions, though turnaround times and scope differ from OFAC.  <\/p>\n\n\n\n

The EU<\/a> takes a more formalist approach. While it avoids extraterritoriality, it imposes best-efforts obligations on EU-linked entities. Enforcement varies by member state, and asset freezes hinge on ownership and control tests. EU sanctions are more frequently litigated, with the European Court of Justice playing a central role. <\/p>\n\n\n\n

This differing picture leaves in-house legal teams with the challenge of avoiding exposure in each jurisdiction while maximising lawful activity. <\/p>\n\n\n\n

To explore different sanctions regimes and compare jurisdictions, visit our <\/em>Sanctions 2025 Global Practice Guide<\/em><\/a>.<\/em> <\/p>\n\n\n\n\n\n

In the face of this ongoing complexity, in-house legal teams are evolving their approach. The goal is no longer just to avoid breaches\u2014it\u2019s to build systems that anticipate change and respond with agility. <\/p>\n\n\n\n\n\n\n\n

Establish escalation frameworks for sanctions-related decisions. Ensure teams know when to seek external advice and how to document risk assessments <\/p>\n\n\n\n

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Track developments across regimes and jurisdictions. Export controls and other sanctions rules are volatile and can shift overnight. <\/p>\n\n\n\n\n\n

In our interviews with general counsel, conducted to compile rankings, many cite the importance of working with law firms that have a nuanced grasp of sanctions risk management. <\/p>\n\n\n\n\n\n

In-House Counsel, Global Technology Company – describing their chosen sanctions law firm<\/em><\/p>\n\n\n\n\n\n\n\n

Ali Mirjani-Arjenan, Principal Research Specialist (Sanctions and International Trade), Chambers and Partners<\/em><\/p>\n\n\n\n

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Our US sanctions rankings<\/a> spotlight elite firms with deep experience in OFAC enforcement, export controls, and cross-border compliance. Many advise Fortune 500 clients and sovereign entities on high-stakes matters ranging from CFIUS filings to ITAR and EAR licensing. Four firms achieved a Band 1 ranking: Akin, Covington & Burling, Hogan Lovells, and Steptoe LLP. <\/p>\n\n\n\n

Our UK sanctions rankings<\/a> recognise the expertise of firms and lawyers who cover advisory work, as well as those representing clients in litigation challenging international sanctions designations. Band 1 firms are Baker McKenzie, Carter-Ruck, Fieldfisher and Peters & Peters. <\/p>\n\n\n\n

Drill into these key areas of competence when assessing a sanctions law firm: <\/p>\n\n\n\n\n\n

Sanctions compliance is rarely domestic. The best firms understand how US, UK, EU, and other regimes interact\u2014and where they diverge. This is essential for multinationals operating across jurisdictions. <\/p>\n\n\n\n\n\n

Sanctions often trigger force majeure, frustration, or change-of-law clauses. But exiting a contract is rarely straightforward. This requires not just legal acumen, but geopolitical fluency and reputational sensitivity. Leading firms guide clients through the nuance\u2014balancing legal risk, commercial pressure, and reputational fallout. <\/p>\n\n\n\n\n\n

Securing permissions to continue lawful operations amid shifting rules is a core function of sanctions counsel. This includes OFAC and OFSI licensing, wind-down arrangements, and humanitarian exemptions. Top firms are proactive in helping clients navigate these processes, often drawing on former government experience and deep agency relationships. <\/p>\n\n\n\n\n\n

Sanctions law is no longer a reactive function: it\u2019s a strategic capability. For in-house counsel, the challenge is to build systems that are agile, informed, and globally attuned. This will enable you to lead with foresight, not just caution.  <\/p>\n\n\n\n

The firms that can help you do this aren\u2019t simply interpreting rules. They\u2019re helping clients expertly navigate shifting regulations, meet compliance obligations, and protect reputation\u2014all while staying operational and commercially competitive. <\/p>\n\n\n\n

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