The UK and US sanctions regime against Russia have notable differences, and President Trump has indicated he may lift certain sanctions. In this week’s NLJ, James Clark, partner, Ian Hargreaves, partner, and James Philippsohn, associate, of Quillon Law, discuss the sanctions landscape and how it applies to businesses and individuals
They note that ‘the US asserts a much broader extraterritorial reach’ than the UK; for example, sanctions can apply if the transaction is conducted in US dollars or clears through the US financial system even if no US person is directly involved. Another crucial difference is the US use of ‘secondary sanctions’, which target non-US persons outside the US.
Clark, Hargreaves and Philippsohn write: ‘It is possible for a transaction to be permitted under US law but a criminal offence under the UK sanctions regime, and vice versa. These differences are likely to increase given the divergence in the US’s and the UK’s approach to Russia.’RELATED ARTICLES
