Economic sanctions increasingly are impacting all aspects of global commerce, targeting not only dealings with traditionally embargoed countries such as Iran, but also transactions with more globally integrated countries such as Russia and China. In recent years, U.S. sanctions have expanded in scope and become more extraterritorial, while the European Union has established its own complex sanctions -- and counter-sanctions -- programs.
The worldwide impact of U.S. sanctions has been notable in recent years, with U.S. authorities levying nine- and ten-figure settlements against non-U.S. entities engaged in trade with countries subject to U.S. embargoes. Other U.S. measures, such as sanctions against major Russian companies and U.S. withdrawal from the nuclear agreement with Iran, present significant challenges for all companies worldwide that operate across borders.
The global scope of U.S. sanctions, along with the emergence of complex EU sanctions and “blocking” measures, warrant careful consideration in the cross-border context.