Full Description
We are pleased to present the 2026 edition of ICLG - Sanctions. We hope that you will
find this year's edition informative.
As this edition is going to print, we can say without a doubt that 2025 has been a year
of tremendous change in the world of international trade and economic sanctions,
and we fully expect 2026 to continue apace.
In the Unites States, the second Trump Administration has brought about a sea
change in the rules and mechanics of global trade and finance, including the focus,
scope and use of sanctions - and counter-sanctions measures - by not only the United
States but also many other countries around the world.
In terms of trend lines, multilateralism appears to be waning. As the Russia-Ukraine
war continues into its fourth year, Europe re-arms, and the U.S. oscillates between
the threat of more sanctions or sanctions relief depending on whether a deal can be
struck, there is an open question as to whether, and to what extent, the United States,
United Kingdom, and European Union will continue to coordinate their Russiarelated
sanctions (see, for example, the already-splintered Russian oil price cap
mechanism). The United States' recent use of certain other sanctions, such as those
targeting International Criminal Court's judges and prosecutors, may also set it at
odds with some or many of its allies.
A potentially impending UN snapback of pre-JCPOA sanctions on Iran would serve
to bolster the Trump Administration's (re)declared "maximum pressure" strategy
targeting Iran's oil revenues, but could prove difficult to implement if Russia, China,
and historically nonaligned states such as India do not observe them.
We have also seen the novel use by the United States of tariffs across the board,
including as a means to threaten or even punish jurisdictions for activity which runs
counter to U.S. sanctions programmes or policies.
U.S. competition with China and the resulting U.S.-China trade war continues to
intensify, with sanctions playing a key role alongside many other tools including
tariffs, import and export controls, inbound and outbound investment controls, and
a growing panoply of other novel laws and regulatory regimes targeting U.S.-China
trade and investment flows. Meanwhile China is not sitting idle, and has continued
to flex its muscle through the increasing use of its various "counter-sanctions"
programmes to target primarily U.S. politicians and companies.
Finally, 2025 has seen a dramatic uptick in sanctions enforcement in other countries,
notably in the United Kingdom through the Office of Financial Sanctions
Implementation, and with the European Union picking up steam as well, particularly
in Germany.
Gibson, Dunn & Crutcher LLP is honored to join a group of industry-leading
colleagues in presenting the following chapters on sanctions across several different
jurisdictions. The following chapters are intended to provide a high-level overview of
sanctions worldwide and pursuant to each enumerated jurisdiction's national laws.
Readers are, of course, encouraged to contact Global Legal Group or the contributors
with further questions, comments, or observations.
Contents
Expert Analysis Chapters
U.S.-China Strategic Competition and the Impact of Economic Statecraft on Global Financial Institutions and Corporates
Adam M. Smith, David A. Wolber, Dharak Bhavsar & Zach Kosbie, Gibson, Dunn & Crutcher LLP
The Prospect of Resuming Business with Russia: Legal and Practical Implications Under EU Sanctions
Salomé Lemasson, SL Avocat
Elena Fedorova, Fedorova Avocat
Trade Sanctions and Compliance Challenges
Neil Whiley, ABC International Bank PLC
Q&A Chapters
Australia
Dennis Miralis, Jack Dennis, Richard Boesel &
Darren Pham, Nyman Gibson Miralis
China
Weiyang (David) Tang, Juanqi (Jessica) Cai,
Siyu (Rain) Wang & Zixuan ( Jessica) Li, JunHe LLP
Czech Republic
Michal Zahradník & Martin Jonek,
DELTA legal, advokátní kancelář s.r.o.
France
William Julié, Amélie Beauchemin, Camille Gosson &
Elena Moreno, WJ Avocats
Germany
Benno Schwarz & Nikita Malevanny,
Gibson, Dunn & Crutcher LLP
Veit Bütterlin-Goldberg & Svea Ottenstein,
AlixPartners
Greece
Ovvadias S. Namias, Vasileios Petropoulos &
Ilias Spyropoulos, Ovvadias S. Namias Law Firm
India
Ayush A Mehrotra, Upkar Agrawal & Varsha Goel,
Khaitan and Co LLP
Japan
Kazuho Nakajima, Hanako Ohwada, Kazuki Yoshii &
Takanori Mizuno, Nishimura & Asahi (Gaikokuho
Kyodo Jigyo)
Poland
Jarosław Kruk, Joanna Bogdańska &
Katarzyna Dawidziuk, KW Kruk and Partners Law Firm
Sweden
Anders Leissner & Tyra Fellbom von Mentzer,
Advokatfirman Vinge KB
Switzerland
Claudio Bazzani, Reto Ferrari-Visca &
Stefan Bindschedler, Homburger AG
USA
Samantha Sewall, Justin duRivage, Sarah Burns &
Hui Fang, Gibson, Dunn & Crutcher LLP
