Secure your compliance program with the rules on sanctions, embargoes and export controls ("Trade Sanctions")

The rules on sanctions-embargoes have been considerably tightened since the beginning of the war in Ukraine, with 13 packages of European sanctions that include trade restrictions (targeting both exports and imports), freezes on financial assets and restrictions on access to the European market.

In addition to the Russian sanctions, there are currently around 40 other sanctions regimes targeting natural and legal persons in more than thirty countries, as well as sectoral embargoes.

These rules also include measures to prevent the circumvention of sanctions (such as concealment or transfer of funds that were to be frozen, concealment of beneficial ownership of property, or failure to provide sufficient information to the authorities).

In addition, the export of Dual-Use Items (which may have civilian, military and security applications) is also subject to strict controls.

On March 12th, the European Parliament adopted a directive aimed at increasing criminal sanctions against European companies that violate these sanctions and embargoes as well as export control rules, with very dissuasive financial penalties and criminal penalties of up to 5 years in prison.

Finally, companies may also be affected by the sanctions-embargo programs decreed by the United States of America if they have a connection to them, taking into account certain extraterritorial applications of American law.

Depending on the geography of your exports, a Sanctions-Embargo compliance program will allow your company to identify, analyze and prioritize the risks of non-compliance with these rules.

This program, which is based on a mapping of the risks of violation of these rules, must also include a system for monitoring the identity of your customers' shareholders and the final destination of sales.

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