Sanctions & Export Controls

We advise individuals and corporates on the implications of EU, Greek and international financial and trade sanctions on their business. We support clients in navigating the rapidly shifting and increasingly complex sanctions regimes, identifying and managing the risks these regimes pose to their business operations, commercial arrangements and strategic transactions, particularly where clients engage in cross-border activity.

Our clients are market leaders in the movement of goods, services, capital and technology across borders. They operate across a broad range of industries, including infrastructure management, energy, media, maritime, digital assets and cryptocurrencies, fintech, ecommerce, healthcare, real estate, transport and defense. Our clients span the private, public and non-profit sectors.

Compliance & Risk
We advise on the legal and regulatory framework governing sanctions, export controls and trade controls, helping clients embed compliance into their commercial arrangements and day-to-day operations. Our team develops tailored compliance programs, policies, group-wide best practice frameworks and internal training for corporates, banks and financial institutions. We prepare and submit authorization and derogation applications, manage disclosures and breach reporting and engage directly with regulators and national competent authorities on behalf of our clients.
Regulatory Proceedings & Disputes
Our team conducts internal audits and investigations in connection with potential or actual sanctions breaches, working swiftly to assess exposure and develop a remediation strategy. We represent clients before regulatory authorities and courts in enforcement proceedings and civil disputes arising from commercial arrangements affected by sanctions.
Transactions
We advise on the impact of sanctions on domestic and cross-border corporate and financial transactions, investments and joint ventures. We work closely with our Corporate and M&A and Banking, Finance & Capital Markets teams in the context of large transactions and due diligence exercises, to ensure the early identification of sanctions risks and the negotiation of robust contractual protections. Where necessary, we advise on restructuring transactions to address sanctions exposure and work to achieve commercially viable risk mitigation.
Recent Experience
Obtaining Derogation in the Pharma Sector
We are advising a multinational pharma group in applying for a derogation under the EU professional services sanctions regime, including preparing the authorisation application, liaising with the authorities and assisting the client through the clearance process while ensuring minimal disruption to the client's ongoing operations.
Strategic Advice on Acquisition in the Energy Sector
We are acting for a global investor in connection with the potential acquisition of a company in the energy sector, including conducting a sanctions risk assessment across jurisdictions, developing tailored risk mitigation strategies and guiding the client through applicable regulatory and licensing requirements.
Advice on Sanctions Compliance for Critical Infrastructure Operations
We are advising a client on compliance with EU sanctions in relation to critical infrastructure activities and their practical application to the client's operational framework.
Advice on Contractual Provisions in the Automotive Sector
We act for an international client operating in the automotive industry in connection with the localization of its terms of business, including the integration of sanctions and export control compliance into its contractual framework.
Navigating the Intersection of EIB Exclusion Rules, RRF Funding and EU Sanctions
We advised a renewable energy provider on the interplay between EIB financing exclusion rules, RRF funding and the EU sanctions regime, including eligibility analysis, compliance risk identification and structuring advice.
Derogation for the Disposal of Claims by an International Financial Institution
We advised an international financial institution on obtaining a derogation under EU sanctions in relation to the sale of claims arising under loan agreements with a listed entity. Our work included drafting the derogation application and engaging with the regulator to secure clearance.
Compliance Advice for a Diversified Corporate Group
We advise a group of companies with diversified operations spanning multiple sectors on the interpretation and application of the EU and international sanctions regimes relating to Russia, including ongoing monitoring of EU, US and UK sanctions developments, risk analysis and assessment of the practical implications of applicable financial and trade sanctions on the client’s operations.
Obtaining Derogation from Finance Restrictions
We advised an international financial institution on compliance with EU sanctions in the context of its capital increase mechanism, including preparing and securing the required authorisation from the regulator and thereby enabling the transaction to proceed in full compliance with applicable restrictions.
Advice to Bond Issuer on Bond Loan Obligations affected by EU Sanctions
We advised a company active in the shipping trading sector on the application of EU sanctions to its operations, with particular focus on the intersection of sanctions and Greek bond loan legislation governing the issuer's obligations where the bondholder is subject to sanctions.
Sanctions Affecting the Aviation Sector
We advised a client on the potential impact of EU sanctions to its activities in the aviation sector, including conducting an assessment of implications on existing contractual arrangements with service providers and identifying areas requiring renegotiation or restructuring to ensure continued compliance.
Sanctions Enforcement Advice in the Shipping Industry
We advised an international client active in the shipping trading sector on the full range of enforcement risks arising from potential breaches, including exposure to administrative, criminal and civil penalties under Greek and EU law, and advising on engagement strategies with the relevant enforcement authorities.
Derogation for Repayment Obligations Owed by Russian Sanctioned Entities
We acted for an international financial institution in obtaining a derogation under the EU asset freeze regime, permitting the repayment of amounts owed by Russian sanctioned entities.