RUSSIA
Planning for the Unexpected: Managing Conflicts of Law, Reassessing Exposure, and Preparing for New Policy Twists and Turns

Brad Brooks-Rubin
Partner
Arktouros PLLC
Former Senior Advisor, U.S. Department of State

Bahman Farahdel
Global Head of Sanctions, Trade and ESG Compliance
Bloomberg LP
Industry is operating in a holding pattern—managing day-to-day compliance amid a sanctions regime that could tighten or unravel with little notice. This panel will explore how to assess exposure, address regulatory misalignment, and plan for the unexpected.
- Managing regulatory divergence between U.S., EU, and UK sanctions regimes, especially during wind-downs or divestments that trigger competing legal obligations
- Understanding the enforcement paradox: Active DOJ and OFAC cases that continue despite speculation about a potential political deal or sanctions rollback
- How to assess reputational, legal, and counterparty risk
- How companies can scenario-plan for abrupt policy changes—including new designations, license revocations, or geopolitical shifts that reopen old enforcement risks
- Keeping your program agile and ready for what’s next