Overview

This alert reviews recent and significant changes to United States and European Union sanctions targeting Syria, Libya, and Iran. These changes are in direct response to events “on the ground” in these countries, and they reflect an increasingly coordinated use of sanctions as tools of foreign policy.

While the US and EU sanctions targeting Libya and Syria differ in several respects, the alert outlines how their broad prohibitions and international reach are combining to create significant legal and compliance challenges, as well as reputational risks, for international companies.

In addition to discussing recent changes to the Libya, Syria and Iran sanctions, this alert surveys sanctions developments arising from South Sudan’s independence, political developments in Belarus, and the famine in Somalia. In addition, the alert provides general observations on ways to manage common compliance issues arising under these increasingly complex and aggressively-enforced legal regimes.

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