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Sanctions & Export Controls

United Kingdom

Sanctions and export controls are now a key risk for companies engaged in international trade. The risk of corporate fines and personal criminal liability, combined with constantly changing regimes reflecting changing political developments makes it a high-risk yet complex area of legal compliance.

CMS has in-depth international sanctions and export controls expertise. Our sanctions team is frequently called upon to advise on the application of sanctions regimes and assist businesses engaged in international trade. We regularly advise on sanctions compliance and controls within a broad range of sectors. 

Sanctions imposed by the EU have a particularly broad reach, affecting businesses that are incorporated outside of the EU or EU individuals working in other countries. The challenge facing businesses is how market participants operating in a global context, in complex supply chains, and in high-risk jurisdictions, can ensure compliance with complex and continually evolving sanctions restrictions. Practical scenarios rarely fall neatly within the wording of the legislative rules, and with little in terms of guidance or case law risk-assessment tends to fall to the commercial decision-makers in business.

We provide practical strategies to navigate the complicated regimes as issues arise, guidance on risk assessment, screening and due diligence, monitoring and reporting. We have experience of liaising with HM Treasury, including submission of licence applications for derogations under the relevant European rules. Our sanctions team advises on the specific aspects of UK enforcement, and works alongside our colleagues across CMS to advise on enforcement at different national levels in the EU.

Our sector focus helps us understand your business environment, and we can help you devise business strategies to address challenges in your market.

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24 June 2020
The UK ex­pands for­eign in­vest­ment con­trols
On 23 June 2020, the UK Gov­ern­ment in­tro­duced a new pub­lic in­terest ground on which it can in­ter­vene in mer­gers: to main­tain UK cap­ab­il­ity to com­bat and mit­ig­ate pub­lic health emer­gen­cies. The UK joins...
23 June 2020
COV­ID-19 – UKIPO re­views and ends peri­od of ‘in­ter­rup­ted days’
The UKIPO has re­viewed the so-called peri­od of ‘in­ter­rup­ted days’ which star­ted on 24 March 2020 and de­cided that the last ‘in­ter­rup­ted day’ will be 29 Ju­ly 2020. An ‘in­ter­rup­ted day’ is defined...
22 June 2020
Free­ports: an Over­view of the Key Is­sues
In­tro­duc­tion The Gov­ern­ment’s Free­ports Con­sulta­tion (the “Con­sulta­tion”) is due to close in just un­der a  month’s time, on 13 Ju­ly 2020. The Con­sulta­tion seeks views on the Gov­ern­ment’s pro­pos­al...
03 June 2020
COV­ID-19 – UKIPO re­views and ex­tends peri­od of ‘in­ter­rup­ted days’
The UKIPO has re­viewed and again ex­ten­ded the so-called peri­od of ‘in­ter­rup­ted days’ which star­ted on 24 March 2020 to at least 22 June 2020. An ‘in­ter­rup­ted day’ is defined as “a day in which...
30 April 2020
COV­ID-19 - EUIPO ex­tends dead­lines
The EUIPO yes­ter­day ex­ten­ded time lim­its which are due to ex­pire between Fri­day, 1 May 2020 and Sunday, 17 May 2020 to Monday, 18 May 2020. This fol­lows the earli­er ex­ten­sion of time lim­its un­til 1 May...
24 April 2020
UK Par­lia­ment­ary in­quiry ex­am­ines the role of the FCO in UK for­eign in­vest­ment...
The UK Par­lia­ment­ary For­eign Af­fairs Com­mit­tee has opened an in­quiry in­to the For­eign and Com­mon­wealth Of­fice (FCO)’s role in block­ing for­eign as­set strip­ping of UK com­pan­ies. The in­quiry comes as there...
21 April 2020
Coty v Amazon: CJEU con­firms Amazon is not li­able for trade mark in­fringe­ment...
On 2 April 2020, the CJEU handed down its judg­ment in the Coty v Amazon[1] case, which relates to a re­fer­ral from the Bundes­gericht­shof, Ger­many’s Fed­er­al Court of Justice. The CJEU ruled in fa­vour...
30 March 2020
EU Com­mis­sion calls for closer scru­tiny of for­eign dir­ect in­vest­ment
Non-EU in­vestors may be con­fron­ted with more ri­gid clear­ance pro­cesses when at­tempt­ing to ac­quire EU com­pan­ies as a res­ult of an un­pre­ced­en­ted call for ac­tion by the European Com­mis­sion. In a policy pa­per...
19 March 2020
Help for busi­nesses in dis­tress due to COV­ID-19
The Gov­ern­ment and Bank of Eng­land have an­nounced a num­ber of schemes and meas­ures to sup­port busi­ness dur­ing the “Cov­id-19 shock”. The de­tails are be­ing de­veloped but what is known so far is sum­mar­ised...
16 March 2020
Coronavir­us – EUIPO and UKIPO pub­lish guid­ance on ex­ten­sion of dead­lines
The UKIPO and EUIPO have today pub­lished guid­ance on the ex­ten­sion of dead­lines. This fol­lows the an­nounce­ment of the WHO that the out­break of the coronavir­us dis­ease (COV­ID-19) can be char­ac­ter­ised as...
26 February 2020
Can­nabis mark ruled con­trary to pub­lic policy
Back­ground On 19 Decem­ber 2016, Ms Santa Conte (“Ms Conte”) made an ap­plic­a­tion to re­gister an EU trade mark for the fol­low­ing fig­ur­at­ive sign in re­la­tion to vari­ous food and drink products and ser­vices...
20 February 2020
Gov­ern­ment con­sults on UK Glob­al Tar­iff
The UK Gov­ern­ment has launched a pub­lic con­sulta­tion on what the UK’s glob­al tar­iff re­gime should be after the end of the trans­ition peri­od with the EU. Changes be­ing con­sidered in­clude re­mov­ing small...