This interactive workshop will delve into the evolving sanctions environment surrounding Russia and focus on real-time decision-making in the face of regulatory divergence. Participants will work through a series of detailed hypotheticals designed to simulate the complex challenges multinational businesses face when navigating sanctions imposed by the U.S., EU, and UK. Emphasis will be placed on cross-border compliance dilemmas and how to work through them.

• Apply knowledge of Russia-related sanctions to fact patterns involving conflicting requirements
• Identify points of regulatory divergence that can create strategic and operational risk, including:
  • Divergent ownership and control thresholds;
  • The impact of U.S. secondary sanctions;
  • Divergent reporting obligations and expectations in each jurisdiction; and
  • Differing exceptions and approaches to licensing with respect to the same sanctioned activity
• Develop proportionate internal decision-making frameworks that align legal, compliance, and business objectives
• Examine the approach to enforcement adopted by key sanctions regulators in the UK, EU and U.S.