Workshop A – Your Updated Roadmap to Global Sanctions Compliance: Aligning U.S. and EU Requirements and Preparing for Future Enforcement Trends
Sean Koehler
Partner
Wiggin and Dana LLP
Renée Latour
Partner
Clifford Chance
As geopolitical priorities diverge and enforcement expectations continue to evolve, multinational organizations face increasing challenges in maintaining a sanctions compliance program that satisfies both U.S. and EU requirements. Differences in ownership and control standards, licensing frameworks, blocking statutes, secondary sanctions exposure, and enforcement priorities require organizations to make complex, risk-based decisions across jurisdictions.
This advanced workshop will examine the practical realities of building and maintaining a global sanctions compliance framework capable of withstanding regulatory scrutiny while supporting business objectives. Through detailed case studies and interactive discussion, participants will explore strategies for addressing regulatory fragmentation, harmonizing controls across jurisdictions, managing conflicting obligations, and preparing for future developments in sanctions policy and enforcement.
Key Learning Objectives:
- Applying U.S. and EU sanctions requirements within a unified global compliance framework while managing regulatory divergence, conflicting legal obligations, and evolving enforcement expectations
- Reconciling competing ownership and control standards across jurisdictions
- Managing conflicts arising from the EU Blocking Statute, U.S. secondary sanctions, and other competing legal obligations that place multinational organizations at the intersection of conflicting regulatory requirements.
- Designing governance structures that support consistent sanctions-related decision-making across regions while balancing local regulatory requirements, enterprise-wide risk management objectives, and evolving enforcement expectations
- Developing adaptive controls that address evolving U.S. and EU sanctions risks related to Russia, Iran, and China, including ownership and control challenges, indirect exposure, sanctions evasion tactics, and increasingly divergent regulatory expectations across jurisdictions
- Evaluating emerging enforcement priorities and regulatory expectations