Global Economic Sanctions

This session will explore the EU’s “best-efforts” approach to compliance with the far-reaching, enforceable nature of US secondary sanctions. We will examine how Trump Administration policies are shaping sanctions on Russia, China, and other jurisdictions, the increasing reliance on export controls, and the practical challenges for multinational companies operating across jurisdictions. The discussion will also address how tariffs, though not legally sanctions, are increasingly used as strategic tools, and what lessons past sanctions regimes offer in this evolving trade environment.

Building on the foundational discussion during the pre-conference workshop, this session explores how to address the most intricate challenges multinational companies face in managing compliance, risk, and strategy across jurisdictions. Points of discussion include:

• Projecting the future of Russia-related sanctions and their alignment (or misalignment) between the U.S., EU, and UK
• Preparing for regulatory divergence that may leave EU companies exposed if U.S. changes sanctions
• Navigating recent UK software and technology sanctions on Russia and divergences from U.S. and EU
• Evaluating whether businesses will re-engage with the Russian market and what risks or incentives might drive that decision
• Anticipating the broader implications for trade, regulatory alignment, and global business strategy
• Ensuring companies stay agile by tracking obligations across multiple legal regimes amid potential expansion of sanctions

• Rising tensions between US and China in the sanctions, export control, and information sharing spaces-and the practical impact
• Addressing challenges for multinationals navigating conflicting legal regimes (e.g., US sanctions vs. Chinese countermeasures)
• Examining U.S. and Chinese enforcement trends, legal risks, and how companies are adapting their structures and compliance strategies
• Managing conflicting laws between US and China and how to manage your subsidiaries and affiliates

• How AI can enhance sanctions screening, improving decision-making efficiency, and reducing operational costs
• Identifying the challenges and risks of overreliance on AI , including concerns about bias, transparency, and accountability
• Determining when to rely on AI outputs and recognizing red flags that warrant a manual review
• Leveraging AI for export compliance, enhancing sanctions screening, managing dual-use concerns, and navigating challenges across the U.S., EU, and China
• Understanding how AI can streamline export control processes, increasing efficiency and ensuring compliance with complex regulations
• Assessing the risks associated with AI integration, particularly how it may misalign with existing export control frameworks and regulatory requirements
• Discussing how companies are managing AI and compliance technologies internally and ensuring proper oversight across global teams

• Examining recent UK sanctions enforcement trends and what they reveal about OFSI’s evolving priorities
• Understanding the role of voluntary disclosures, strict liability, and how regulators weigh strong compliance programs that don’t fully prevent breaches
• Discussing whether/how/when the best-efforts provision could be enforced against all related EU parent companies (such as, even if the ultimate parent company is non-EU and there is more than one EU-based sub-holding company).
• Identifying best practices and lessons learned from enforcement actions to strengthen internal controls and meet OFSI expectations

Our speakers will examine current and future sanctions scenarios, the impact of Belarus’s alignment with Russia, and the human rights-based sanctions landscape. Featuring voices from investigative journalism, freight compliance, financial crime, and human rights, the panel will offer a multifaceted legal and practical perspective for sanctions practitioners.

• Exploring real-world examples and lessons learned of how sanctions are being applied in Iran, Yemen and other key jurisdictions in the region
• Conducting internal investigations across multiple jurisdictions, while ensuring compliance with overlapping and sometimes conflicting legal regimes
• Exploring the potential impact of a new nuclear deal on US sanctions against Iran and how this could reshape the geopolitical landscape
• How should companies and policymakers adjust their risk management frameworks to anticipate future changes in Iran sanctions programs and global trade regulations?

This session will explore the U.S.’ unprecedented use of “secondary tariffs” targeting countries that import Venezuelan oil, including potential implications for EU exporters. These discretionary tariffs, applied to all goods entering the U.S. from such countries, introduce a new dimension to transatlantic sanctions compliance. We will examine how this trade-focused enforcement tool differs from traditional secondary sanctions and its relevance to EU firms engaged in global energy markets. The discussion will also assess jurisdictional challenges, enforcement discretion, and risk mitigation strategies.

• Identifying the latest trends in sanctions circumvention and how evasion methods are evolving across sectors
• Strengthening internal compliance frameworks to detect and prevent violations before new regulations are in place to tackle new sanctions
• Recognising red flags and key warning signs for circumvention in financial transactions, trade activity, and corporate structures
• Meeting OFSI’s expectations for circumvention prevention
• The growing intersection between sanctions and export controls, particularly for banks and financial institutions

Cross-border investigations often come with legal, cultural, and logistical hurdles. This session will explore the real-world challenges companies face when trying to get to the bottom of a problem across different jurisdictions, including difficulties with data access, local laws, and coordination between offices. It will also cover the best practices companies are adopting to stay compliant, manage risk, and handle sensitive issues effectively in a global context.

As digital tools advance, encryption and cryptography are becoming a growing focus in export controls. This session will look at how these technologies are regulated and why they are playing a bigger role in the sanctions world. Points of discussion include:

• Highlighting why the export of cryptographic tools and encryption software is often less obvious, but just as critical
• Proposing the integration of encryption into sanctions regimes as a strategic extension of compliance frameworks
• Exploring existing trade restrictions: which goods and software are covered, and which jurisdictions are affected
• The export control implications of software and cryptographic technologies in relation to high-risk countries, particularly Russia