Sanctions Compliance and Litigation
We represent businesses, individuals, government officials, and foreign politicians who have had sanctioned imposed on them. We advise small and mid-sized banks whose clients are placed on one or more sanctions lists. Similarly, individuals and companies that find themselves dealing with sanctioned individuals or that find themselves sanctioned turn to us for guidance, particularly in cases where the sanctions listing was based on incomplete or incorrect information.
Our broad international practice allows us to help clients who face sanctions in multiple countries. We operate as our client’s single point of contact, providing efficient and effective ways to coordinate responses in a multi-country sanctions situation.
Types of Sanctions
Our experience includes sanctions imposed under the following US laws, Regulations, and Executive Orders:
- The Global Magnitsky Act, which is used to impose sanctions on individuals and companies believed to be responsible for human rights abuses or serious acts of corruption. Potential sanctions include blocking or revoking US visas, and a freeze on US-based property and other assets. The UK, Canada, and the EU have enacted similar sanctions laws.
- Section 7031(c) bans, which allow the Department of State to deny foreign officials and their immediate family members entry into the United States, can be imposed where the United States has “credible evidence” that the official was involved in “significant corruption, including corruption related to the extraction of natural resources, or a gross violation of human rights.”
When Your Customer Is Sanctioned
Businesses whose customers have been sanctioned, particularly customers with US-based assets, must exercise care and balance their obligations to their clients with their obligations to comply with the relevant sanctions law. We regularly help businesses understand their obligations to their clients and in complying with the relevant sanctions laws.
It’s not unusual for the US and other governments to impose sanctions based on less than complete information. We help clients who have been added to one or more sanctions lists based on faulty evidence to contest the listing, either by suing the governmental body that imposed the sanctions or by pursuing internal processes made available by that governmental body. We have been successful in helping our clients lift sanctions that were wrongfully imposed.
Contact Williams LLP to Learn More
Contact Williams LLP to schedule a consultation to learn more about how we can help.