Sanctions & Export Controls

We assist our clients with their matters in the field of international trade, economic sanctions and export control regulations, helping them to navigate the complex patchwork of these regulations which are known for rapid change, overlap, broad scope and strict enforcement. We advise on the permissibility of transactions and the applicability of license requirements and other restrictions. If so desired, we assist clients in obtaining the necessary clearance from authorities, ranging from classification decisions to export licenses.

We also regularly conduct internal investigations into economic sanctions and export control related matters. We have ample experience in representing clients in economic sanctions and export controls related enforcement matters vis-à-vis various regulatory and criminal authorities. These include the:

• U.S. Office of Foreign Assets Control (OFAC),
• U.S. Bureau of Industry and Security (BIS),
• Department of Justice (DoJ),
• Dutch Ministry of Foreign Affairs; and
• Dutch Central Department for Import and Export (CDIU).

We also advise a range of financial institutions on the specific requirements that apply to them in relation to economic sanctions and related governance issues, closely cooperating with our colleagues in our Financial Markets Regulation practice. Similarly, together with our M&A and Competition colleagues, we advise on transactions and foreign direct investment screening relating to strategic investments, notably those involving sensitive technologies.

As matters in this field often involve various jurisdictions, we keep close ties with specialised foreign counsel, including in the U.S. and the U.K., while the quickly evolving developments in China are covered by our own Shanghai office.

Our clients include multinational corporates and financials, based in the Netherlands and abroad. Clients value our advice for our multidisciplinary approach and ability to provide effective solutions, aligning corporate and commercial goals with legal compliance. In enforcement matters they choose us for our broad, multinational experience and ability to handle cross-border internal and regulatory investigations in close coordination with foreign counsel and authorities.