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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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30 Mar 20
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 Mar 20
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 Mar 20
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 Feb 20
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 Feb 20
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...
23 Dec 19
Shift­ing Land­scapes: Re­cent De­vel­op­ments in UK For­eign In­vest­ment...
There has been a flurry of activ­ity re­lat­ing to for­eign in­vest­ment con­trol in the short peri­od of time between the res­ult of the gen­er­al elec­tion and Par­lia­ment’s Christ­mas re­cess. On 19 Decem­ber 2019,...
12 Sep 19
UK food and cos­met­ic pro­du­cers to the EU to face new reg­u­la­tions after...
As Brexit draws near­er and with the like­li­hood of an un­reg­u­lated exit still not off the table, EU-27 com­pan­ies im­port­ing or selling food or cos­met­ics from Great Bri­tain face li­ab­il­ity risks if they con­tin­ue...
14 Jun 19
The EUIPO de­liv­ers its ver­dict on the long­stand­ing dis­pute between...
EUTM Can­cel­la­tion Ac­tion: (1) Pro­mote Ice­land, (2) The Iceland­ic Min­istry for For­eign Af­fairs and (3) SA – Busi­ness Ice­land v. Ice­land Foods Lim­ited. Back­ground Three Iceland­ic au­thor­it­ies (“Iceland­ic...