Conquer Complexity: How to Navigate Risk and Select a Sanctions Law Firm
In today’s fluid regulatory environment, general counsel (GCs) increasingly turn to specialist advisors to protect their sanctions compliance.
Sanctions law has shifted from a niche concern to a strategic must-have. Since 2022, restrictions have increased rapidly, chiefly in response to Russia’s invasion of Ukraine. What’s more, differing applications by different regimes make it tricky to stay compliant while doing business effectively. Here we explore the vital issues and how in-house legal should assess a sanctions law firm with Ali Mirjani-Arjenan, Principal Research Specialist (Sanctions and International Trade)
In this Article:
A Unique Challenge: Russia Sanctions
Navigating Different Jurisdictions
A New Approach to Sanctions Risk Management
What GCs Should Look For in a Sanctions Law Firm
Conclusion and Key Takeaways
A Unique Challenge: Russia Sanctions
Since 2022 there has been a 311% increase in measures targeting Russia. Unlike other sanctioned states such as North Korea or Iran, Russian entities had deep ties to global supply chains, investment portfolios, and corporate contracts. From energy contracts to real estate holdings, the challenge wasn’t just legal—it was structural.
“Russia was deeply integrated into Western financial and commercial systems. Unwinding these relationships was far more complex. That’s why sanctions risk management has become a much bigger issue for the GC of a company that trades in London, New York, or Paris, for example. The invasion triggered a wave of new sanctions regimes, often developed rapidly and without precedent. GCs now need to be far more proactive and strategic.”
Ali Mirjani-Arjenan, Principal Research Specialist (Sanctions and International Trade), Chambers
The package of new restrictions put in place covered both major areas of sanctions compliance law, against the regime and against individual entities and actors (designation and delisting).
This article focuses on regime-wide restrictions, which are the main component of sanctions risk management for the majority of in-house teams.
Navigating Different Jurisdictions
One of the most challenging aspects of sanctions compliance is the divergence between regimes. While the US, UK and EU often align on high-level targets such as Russia, their enforcement models and risk thresholds differ in ways that can expose even cautious companies to liability.
The US, via OFAC, applies strict liability and aggressively enforces secondary sanctions—even against non-US entities. Export controls and licensing requirements add further complexity, especially for US-origin goods and dollar-denominated transactions.
The UK, through OFSI, also applies strict liability but focuses on administrative enforcement. Companies must show they’ve taken “reasonable measures” to prevent breaches. Licensing is required for certain transactions, though turnaround times and scope differ from OFAC.
The EU takes a more formalist approach. While it avoids extraterritoriality, it imposes best-efforts obligations on EU-linked entities. Enforcement varies by member state, and asset freezes hinge on ownership and control tests. EU sanctions are more frequently litigated, with the European Court of Justice playing a central role.
This differing picture leaves in-house legal teams with the challenge of avoiding exposure in each jurisdiction while maximising lawful activity.
To explore different sanctions regimes and compare jurisdictions, visit our Sanctions 2025 Global Practice Guide.
A New Approach to Sanctions Risk Management
In the face of this ongoing complexity, in-house legal teams are evolving their approach. The goal is no longer just to avoid breaches—it’s to build systems that anticipate change and respond with agility.
Set Up Specific Internal Processes
Establish escalation frameworks for sanctions-related decisions. Ensure teams know when to seek external advice and how to document risk assessments
Monitor the Rules Continuously
Track developments across regimes and jurisdictions. Export controls and other sanctions rules are volatile and can shift overnight.
Engage the Right External Counsel
In our interviews with general counsel, conducted to compile rankings, many cite the importance of working with law firms that have a nuanced grasp of sanctions risk management.
"They not only stay on top of the latest changes in UK and EU export controls and sanctions laws but also provide tailored, actionable guidance to help navigate complex compliance challenges."
In-House Counsel, Global Technology Company - describing their chosen sanctions law firm
What GCs Should Look for in a Sanctions Law Firm
“The shifting rules can make it feel like treading water the entire time. You need people who are abreast of competing developments in different jurisdictions—and have the ability to disentangle from agreements which have become politically tenuous.”
Ali Mirjani-Arjenan, Principal Research Specialist (Sanctions and International Trade), Chambers
Our US sanctions rankings spotlight elite firms with deep experience in OFAC enforcement, export controls, and cross-border compliance. Many advise Fortune 500 clients and sovereign entities on high-stakes matters ranging from CFIUS filings to ITAR and EAR licensing. Four firms achieved a Band 1 ranking: Akin, Covington & Burling, Hogan Lovells, and Steptoe LLP.
Our UK sanctions rankings recognise the expertise of firms and lawyers who cover advisory work, as well as those representing clients in litigation challenging international sanctions designations. Band 1 firms are Baker McKenzie, Carter-Ruck, Fieldfisher and Peters & Peters.
Drill into these key areas of competence when assessing a sanctions law firm:
Cross-Regime Expertise
Sanctions compliance is rarely domestic. The best firms understand how US, UK, EU, and other regimes interact—and where they diverge. This is essential for multinationals operating across jurisdictions.
Unwinding Contractual Obligations
Sanctions often trigger force majeure, frustration, or change-of-law clauses. But exiting a contract is rarely straightforward. This requires not just legal acumen, but geopolitical fluency and reputational sensitivity. Leading firms guide clients through the nuance—balancing legal risk, commercial pressure, and reputational fallout.
Licensing and Regulatory Engagement
Securing permissions to continue lawful operations amid shifting rules is a core function of sanctions counsel. This includes OFAC and OFSI licensing, wind-down arrangements, and humanitarian exemptions. Top firms are proactive in helping clients navigate these processes, often drawing on former government experience and deep agency relationships.
Conclusion: Stay Compliant and Competitive
Sanctions law is no longer a reactive function: it’s a strategic capability. For in-house counsel, the challenge is to build systems that are agile, informed, and globally attuned. This will enable you to lead with foresight, not just caution.
The firms that can help you do this aren’t simply interpreting rules. They’re helping clients expertly navigate shifting regulations, meet compliance obligations, and protect reputation—all while staying operational and commercially competitive.
Key Takeaways
- Russia’s deep integration into Western systems has made sanctions compliance structurally complex, forcing legal teams to rethink legacy contracts, investments, and reputational exposure.
- The US, UK, and EU sanctions regimes differ in enforcement style, liability thresholds, and licensing expectations, requiring in-house teams to monitor and adapt across jurisdictions.
- Effective sanctions risk management now demands internal escalation protocols, real-time regulatory tracking, and external counsel with licensing and cross-border expertise.
- Leading law firms distinguish themselves by helping clients unwind politically sensitive obligations, navigate force majeure clauses, and secure regulatory permissions to continue lawful operations.
- Chambers’ sanctions rankings offer a clear lens into which firms combine technical precision with strategic fluency—making them indispensable partners in a volatile global landscape.
Conquer Complexity with Clarity
Whether you're advising the board or reviewing contracts, get the clarity you need with the Chambers Sanctions 2025 Global Practice Guide—covering enforcement trends, cross-border risks, and different jurisdictions.