Economic sanctions generally aim to restrict trade and financial relations on the basis of foreign or security policy grounds. Sanctions can be direct or indirect, targeting countries, companies or individuals. They can take the form of trade barriers, embargos, quotas, tariffs or restrictions on financial transactions. Further, shifting government and political interests mean that economic sanctions are inherently fluid, with their subjects and scope continually changing. Economic sanctions pose a complicated and highly-technical legal compliance challenge for companies which operate on the global stage.
Moroğlu Arseven advises clients on the many intricacies and regulatory compliance aspects of multiple sanctions regimes. These include schemes managed by the United Nations, the United States, European Union and the United Kingdom.
Economic sanctions typically involve a maze of conflicting interests, as well as complex regulations, procedures and exceptions. Moroğlu Arseven works closely with clients to develop proactive compliance strategies for their global operations to address these challenges. We support clients during examinations, voluntary disclosures, transactional due diligence, administrative processes, implementing remedial measures, as well as all aspects of regulatory relations and participating in investigations. The firm often supports clients to develop internal compliance or know-your-customer programs and in-house training programs, as well as conduct sensitive internal investigations into potential violations. We also assist with related or consequential issues, such as liability for transaction intermediaries or facilitators, as well as banking secrecy and data protection compliance.
The firm has particular experience supporting clients to deal with issues which involve the United States’ Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN).