Sanctions and Export Control INTERNATIONAL PRACTICES

Sanctions and export controls have become front-page news as both a foreign policy tool and a compliance challenge. With a broad footprint, WilmerHale brings a global perspective to these issues.

US sanctions and export control compliance is increasingly top-of-mind for both management and in-house compliance counsel. The US regulatory landscape includes the Departments of Treasury, State and Commerce, each with its own policy interests, prohibitions, licensing standards and compliance requirements. Violations can lead to severe consequences, including corporate and individual criminal liability, civil money penalties, and administrative sanctions. Our lawyers have extensive experience dealing with the relevant agencies and policymakers, including the Office of Foreign Assets Control, Bureau of Industry and Security, Directorate of Defense Trade Controls, and others. We know them well and are known to them, enabling us to effectively represent our clients' interests on routine and complex matters alike. Our lawyers have the knowledge, experience and global reach to provide comprehensive compliance, licensing, enforcement and policy counsel to a wide range of clients, from early-stage companies to universities and large, multinational corporations.

Issues in the EU

In the EU, both the European Commission and individual Member State authorities shape the policy, compliance and enforcement landscape. Increasingly, the extent of US-EU harmonization on export control and sanctions issues has a direct impact on companies' operations and their ability to manage key risks and compliance challenges.

Our lawyers have extensive experience advising on intra-EU policy, compliance and enforcement issues and assisting clients in successfully navigating the complexities that arise when US requirements diverge with those in the EU and other jurisdictions.


Our experience includes:

  • obtaining licenses for a major US film production to shoot in Cuba following the renewal of US-Cuba diplomatic relations and relaxed US sanctions;
  • conducting an internal investigation and submitting a disclosure for a global technology firm relating to the indirect export of services to Iran;
  • providing sanctions policy and compliance advice to clients in the energy, financial services and business consulting sectors on sectoral sanctions against Russia;
  • conducting a comprehensive assessment of the export control and sanctions compliance program of a leading civil engineering company and providing recommendations to its audit committee;
  • developing training materials for a US oilfield services firm and delivering in-person training to its staff in North America, South America and the Middle East;
  • assisting a major defense firm with its internal review of apparent violations of the EAR, ITAR and FTR, and preparing voluntary self-disclosures that led to optimal outcomes;
  • providing the full range of sanctions counseling for large European and US financial institutions and financial services firms, including in transactional, compliance and enforcement contexts; and
  • advising US owners of a Middle East shipping and logistics business to prepare for and remain compliant with changes to Iran sanctions under the Joint Comprehensive Plan of Action.