Home / Europe / United Kingdom / Competition / Sanctions & Export Controls

Sanctions & Export Controls

Back to Competition

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.

Law-Now: Com­pet­i­tion
Vis­it Law-Now for leg­al know-how and com­ment­ary
Ad­vising the Board


Twenty's Plenty: Free­dom of In­form­a­tion re­form, twenty years on?
Twenty years since the Free­dom of In­form­a­tion (Scot­land) Act 2002 was in­tro­duced, a con­sulta­tion based on a pro­posed Free­dom of In­form­a­tion Re­form (Scot­land) Bill has been launched (clos­ing on 02 Feb­ru­ary...
Rus­sia sanc­tions up­date: UK in­tro­duces new sanc­tions against Rus­sia
Fresh UK sanc­tions reg­u­la­tions have been in­tro­duced im­pos­ing fur­ther re­stric­tions on do­ing busi­ness with Rus­sia in light of Rus­sia’s re­cent an­nex­a­tion of four Ukrain­i­an re­gions. The fif­teenth amend­ment...
Di­git­al Mar­kets Act (DMA) comes in­to force on 1 Novem­ber 2022
The Di­git­al Mar­ket Act (DMA) was pub­lished in the Of­fi­cial Journ­al of the European Uni­on on 12 Oc­to­ber, and it will enter in­to force on 1 Novem­ber. Large di­git­al plat­forms that of­fer core plat­form ser­vices...
UPC Rules of Pro­ced­ure go in­to force with judg­ments to be made pub­lic
The entry in­to force of the Rules of Pro­ced­ure is part of the fi­nal pre­par­a­tions for the United Pat­ent Court (UPC), which is cur­rently ex­pec­ted to start work in early 2023. After the bod­ies of the UPC...
De­tailed scru­tiny needed to make the Pro­cure­ment Bill de­liv­er against its...
The Pro­cure­ment Bill in­tro­duced to Par­lia­ment in May goes to Com­mit­tee Stage in the House of Lords this week. The polit­ic­al am­bi­tion be­hind the pro­posed le­gis­la­tion has been clearly voiced, but does not...
UK Sub­sidy Con­trol re­gime: Roy­al As­sent
On 28 April 2022, the Sub­sidy Con­trol Bill re­ceived Roy­al As­sent, form­ally mak­ing the Bill in­to an Act of Par­lia­ment – the Sub­sidy Con­trol Act 2022.  However, as high­lighted in our ho­ri­zon scan­ning...
Post-Brexit: UK plaintiffs must provide cost se­cur­ity for pro­ceed­ings in...
Last year, long lorry jams made it clear to every­one what con­sequences Brexit will have for cross­ing the bor­der to main­land Europe. Far less known is the hurdle which UK com­pan­ies must over­come when they...
Im­pact of Rus­si­an sanc­tions on the avi­ation in­dustry – up­date on UK Sanc­tions
Fol­low­ing an an­nounce­ment on 3 March, the UK Gov­ern­ment pub­lished le­gis­la­tion im­ple­ment­ing new sanc­tions re­lat­ing to the avi­ation in­dustry.  The Rus­sia (Sanc­tions) (EU Exit) (Amend­ment) (No.6) Reg­u­la­tions...
EU Opin­ion on the Pro­posed Product Safety Reg­u­la­tion
The European Com­mis­sion has put for­ward a pro­pos­al for a new re­freshed Reg­u­la­tion on product safety in line with the New Con­sumer Agenda (the “Pro­posed Reg­u­la­tion”). If passed in its cur­rent form...
Im­pact of Rus­si­an sanc­tions on the avi­ation in­dustry
On 25 Feb­ru­ary 2022, fol­low­ing the Rus­si­an in­va­sion of Ukraine,  the EU in­tro­duced a ban on cer­tain ex­ports in­to Rus­sia im­pact­ing the avi­ation and the space in­dustry. The EU has pro­hib­ited the pro­vi­sion...
Pub­lic pro­cure­ment – new thresholds for 2022
The pub­lic pro­cure­ment thresholds have changed for the United King­dom (Eng­land and Wales, North­ern Ire­land and Scot­land), ef­fect­ive from 1 Janu­ary 2022.  These changes are com­mu­nic­ated in Pro­cure­ment...
Post-Brexit pro­cure­ment re­forms to take shape in 2022
Earli­er this month, the Cab­in­et Of­fice pub­lished its plans for trans­form­ing pub­lic pro­cure­ment rules post-Brexit. The plans in­volve in­tro­du­cing le­gis­la­tion next year to be ad­op­ted and im­ple­men­ted though...