Sanctions

Three Raymond Buildings is a leading financial crime chambers with experience in complex multi-jurisdictional cases. We have a well-established practice acting for financial institutions, insurance firms, law firms and other commercial organisations, as well as individuals, in financial sanctions and export controls cases.  In particular, a significant number of members of chambers are currently engaged in financial, travel and trade sanctions cases arising from the Russian invasion of Ukraine and the application of the Russia (Sanctions) (EU Exit) Regulations 2019/855.

We understand the interplay between legal requirements, public policy and commercial considerations, to ensure that businesses can continue to operate effectively within the framework of international sanctions laws and export controls. Our position at the forefront of white collar and financial services crime and extradition means we are particularly well placed to act where there is the threat of enforcement action against individuals or corporates. Much of our work is confidential and we are proud of our successes in helping clients avoid such action or negotiate appropriate settlements.

Members of Chambers provide advice and representation at all stages of sanctions and export controls cases, including:

• the sanctions/export control implications of potential transactions
• in dynamic commercial situations with evolving sanctions and export controls
• commercial disputes
• effectively responding to suspected non-compliance: lawfulness of current or historic transactions; internal investigations; reporting to regulators; dealing with counterparties
• strategic liaison with domestic and overseas regulators, including HMRC, OFSI and OFAC
• interviews under caution for sanctions and export control related offences and witness interviews under compulsory powers
• challenging designated status under sanctions regimes
• advocacy at trial and on appeal
• expert evidence on the jurisdictional reach of national laws in commercial disputes

Our barristers have experience in advising on UN, US, EU and UK sanctions regimes and on restrictions relating to Russia, Crimea, Syria, Iran, Somalia and other states. We have senior and junior barristers who are jointly qualified in other jurisdictions, including the US, in EU member states and commonwealth countries. Chambers has particular expertise in the application of US sanctions and US sanctions-related extradition requests and in advising on the Russian and Iranian sanctions regimes, including the successful negotiation of appropriate outcomes following breaches of Iranian export controls. Members have successfully represented a number of clients in UN Security Council sanctions delisting petitions before the UN Ombudsperson.

We are currently working with various civil society organisations on the use of sanctions as tools of human rights accountability.

Members of chambers are experienced in providing sanctions and export controls lectures and training to both the private and public sector, domestically and abroad. This has included advising global law firms, international banks, the Department for International Trade, and teaching a university course on international economic sanctions. We also write about developments in sanctions law and are proud to be part of the editorial team of Practitioners’ Guide to Sanctions (GIR 2020 and 2021 editions) and authors of the chapter on UK sanctions enforcement.