The application of the anti-circumvention provisions in sanction cases

As part of our commercial law breakfast seminars for 2015, Jonathan Fisher QC considered what type of conduct is caught by the anti-circumvention criminal offence in EU sanctions legislation, on the morning of Tuesday 3rd March 2015.

Why attend?

Sanctions have been used, originally as an instrument of war, since antiquity. In the modern era, governments continue to employ sanctions and embargoes as an instrument of foreign policy, usually under the premise of maintaining or restoring international peace and security. Their use seems likely only to increase, particularly given Western governments’ increasing reluctance, or inability, to put “boots on the ground”.

The impact of sanctions on business is potentially significant: they can disrupt the performance of contracts, give rise to money-laundering and reporting obligations, or even impact on how groups structure their operations.

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The application of the anti-circumvention provisions in sanction cases

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