Bird & Bird & Sanctions: Enhanced compliance and screening

By Brian Mulier, Goran Danilovic, Dick Ignacio


EU sanctions compliance does not stop at the EU border or with the screening of direct business partners. In view of adhering to the EU sanctions and managing related compliance and liability risks, EU entities must also ensure refraining from any indirect business with sanctioned parties as well as ascertain their owned or controlled non-EU entities do the same.

EU sanctions violations

Violation of the EU sanctions results in (criminal) liability for EU entities and hence, may lead to financial penalties and even imprisonment for the management of the EU entity concerned (in a worst-case scenario). Such violations include indirect trade with sanctioned parties as well as trade via non-EU entities resulting into circumvention.

Learn how to prevent violations in the full report here.