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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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23/07/2021
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Com­pet­i­tion & Mar­kets Au­thor­ity loses con­sumer re­dress test case
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24/06/2021
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16/06/2021
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04/06/2021
UK’s new Trade Rem­ed­ies Au­thor­ity opens for busi­ness
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01/06/2021
Some leaks can­'t be fixed
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11/05/2021
Post-Brexit le­gis­la­tion on pub­lic pro­cure­ment and sub­sidy con­trol an­nounced...
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19/04/2021
Free­ports: New per­mit­ted de­vel­op­ment rights
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11/01/2021
The UK’s new sub­sidy con­trol re­gime 
From 1 Janu­ary 2021, the EU State aid rules no longer ap­ply to fund­ing and oth­er forms of sup­port meas­ures gran­ted to busi­ness by UK pub­lic au­thor­it­ies. The only ex­cep­tions to this are for aid that is...
17/12/2020
Trans­form­ing Pub­lic Pro­cure­ment – the Fi­nal Fron­ti­er?
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12/11/2020
New man­dat­ory UK FDI re­gime to con­trol for­eign in­vest­ment
On 11 Novem­ber 2020, over two years after the White Pa­per on Na­tion­al Se­cur­ity and In­vest­ment in­tro­duced by Theresa May’s Gov­ern­ment, the UK Gov­ern­ment fi­nally pub­lished its long-awaited Na­tion­al Se­cur­ity...