Doughty Street International brings unrivalled inter-disciplinary expertise  to help businesses, individuals and human rights organisations navigate the complexities of international sanctions regimes.

Members of the team advise and represent individuals subject to sanctions, travel bans and asset freezes under the United Nations and UK sanctions regimes, as well as persons subject to or at risk of such measures in foreign jurisdictions.

Sanctions law is a highly technical and fast-moving area of the law, where it is essential for affected companies and individuals to receive timely professional advice.

Our interdisciplinary team is well-placed to advise on the range of related issues that may arise in such cases, including extradition, INTERPOL red notices, engagement with international human rights mechanisms, and reputation management.

Global Human Rights and Global Anti-Corruption Sanctions

Members of Doughty Street International are a first choice for individuals and human Rights organisations seeking to engage targeted sanctions regimes, such as the UK’s Global Human Rights Sanctions Regulations (Magnitsky Sanctions) and Global Anti-Corruption Regulations, to hold individuals and entities involved in grave human rights violations and corruption accountable.

Our members regularly advise government on the implementation of domestic legislation required to enforce Magnitsky sanctions, and on the engagement and enforcement of targeted sanctions regimes.

Recent work includes:

  • Members of the team have been invited to join a legal Task Force on Accountability for Crimes Committed in Ukraine to support Ukraine in delivering justice for victims of international crimes committed by Russia in Ukraine.  We also advise the Ukraine Justice Alliance on the “From Sanctions to Reparations” project.

  • Team members currently advise the FCDO on engaging the UK targeted sanctions regime in relation to the conflict in Ukraine.

  • Geoffrey Robertson QC and Amal Clooney each made submissions to the Parliament of Australia on the implementation of a Magnitsky law on global human rights sanctions.

  • Tatyana Eatwell has advised Redress in the preparation of dossiers of evidence to the FCDO calling for the sanctions against senior officials and entities of third States involved in grave human rights violations.

Publications:

  • Amal Clooney authored the recent International Bar Association’s report on “The Use of Targeted Sanctions to Protect Journalists”.

  • Geoffrey Robertson QC’s recent book, “Plan B for Human Rights”: the network of “Magnitsky laws”, explains the history, current status (in 31 countries) and future possibilities of Magnitsky legislation.  A discussion of these issues at the launch of the book, presented with Amal Clooney and Bill Browder, (formerly Sergei Magnitsky’s client who is accredited with sponsoring the first Magnitsky Act in the US), can be viewed here.

Sanctions Compliance and Enforcement

Sanctions law is a multi-layered arena, with UK, EU and US sanctions schemes often targeting the same individuals and companies in different ways.  Penalties for non-compliance with sanctions can be severe and carry significant costs for personal and professional reputations.

We advise companies and individuals in relation to sanctions compliance, licensing and remedies available to challenge penalties and even the imposition of sanctions. Our members are ranked in Band 1 for international criminal law (Legal 500) and Chambers UK.

Following the escalation of the conflict in Ukraine there has been an upsurge in designations under the Russia Sanctions EU Exit Regulations 2019 /855.  Further, the amendments brought about by the Economic Crime (Transparency and Enforcement) Act 2022 have created a procedure for urgent designations adopting the sanctions law of some foreign jurisdictions into UK law.

Members of the team can respond to requests for advice that are often both urgent and highly sensitive.  For example:

  • We provided urgent advice to a UK manufacturer in respect of prior contractual obligations for the supply of goods to a purchaser with strong ties to designated individual.

  • We acted on behalf of a corporate trust provider in relation to off-shore compliance with UK Regulations in respect of assets formerly owned by designated individual.

  • We advised on licensing in respect of designated individuals to permit the release of frozen assets for school fees and legal expenses.

  • We advised a multinational corporation on exposure to capital market restrictions.

We can also advise on applying for licences from the US Treasury’s Office of Foreign Assets Control (OFAC), applying to the UN Focal Point for the de-listing of individuals and applying for licences for basic living expenses from HM Treasury.

Enforcement

The sanctions enforcement climate in the UK is changing.  In their joint statement the Bank of England and Office for Financial Sanctions Implementation (OFSI) has given a clear indication that criminal prosecution will be considered for breaches of the Russia Regulations. 

Whilst civil penalties remain the norm for breaches of financial sanctions, there is no doubt that following the 2021 update to its monetary penalty guidance, OFSI is now taking a harder line on the assessment of the underlying conduct.  Recent capacity building within OFSI itself indicates that the agency is gearing up for a more strenuous enforcement policy.

Members of the team can advise professionals and business on their disclosure obligations to minimise enforcement risks and manage the adverse reputational consequences of sanctions enforcement.

International Sanctions and De-Listing

Members of the team have advised and represented individuals subject to travel bans and asset freezes under the various United Nations Sanctions asset-freezing regimes before domestic courts, the European Court of Justice and the United Nations mechanisms.

We have expertise in both UN terrorism sanctions regimes and country-specific regimes (having acted in relation to UN Sanctions regimes concerning Libya, Iraq, Sierra Leone and Liberia as well as listings in respect of the United Nations Al-Qaeda and ISIS Sanctions Committee), and are well-placed to advise individuals and entities placed on the UN Consolidated List about de-listing procedures and avenues for redress.

We have been successful in several high-profile cases in having clients removed from UN and/or UK sanctions lists, including: the cases of Agnes Reeves-Taylor (the ex-wife of the former President of Liberia, Charles Taylor), Saad Al-Fagih (a Saudi Arabian opposition figure) and Ismail Bhuta (subject to HM Treasury sanctions).

Members of our team are on the roster of lawyers for the UN Office of the Ombudsperson to the ISIL and Al-Qaida Sanctions Committee.

DSI team members practising in the United States can assist with US Treasury and State Department sanctions against clients.