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Sophie Davis is a counsel in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

On August 28, France, Germany, and the UK (the E3) initiated a “snapback” process that will reimpose UN sanctions on Iran on September 27 unless the Security Council acts. On September 19, a resolution to extend sanctions relief failed to receive sufficient votes at the Security Council and was not adopted. If snapback occurs, previously

In November 2024, the UK Government introduced regulations which granted its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers. Our previous blog post on these amendments can be found here.

The changes included the extension of mandatory financial sanctions reporting obligations (“

The UK’s Office of Financial Sanctions Implementation (“OFSI”) has imposed a monetary penalty of £465,000 against a multinational law firm’s Russian office (the “Russian Office”) for breaching UK financial sanctions against Russia following its invasion of Ukraine in February 2022.  This is the first time OFSI has enforced against a law

As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary

To kick-start 2025, the UK’s recently established Office of Trade Sanctions Implementation (“OTSI”) has published two related guidance notes for UK exporters on Russian trade sanctions evasion and diversion.

First, Countering Russian sanctions evasion – guidance for exporters seeks to support UK exporters and manufacturers in identifying Russian evasion practices and mitigating the

The UK Government has passed new amending sanctions regulations which grants its financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – greater intelligence gathering and enforcement powers, and enables OFSI to deal with licensing applications more efficiently.   

The majority of the amendments introduced by The Sanctions (EU Exit) (Miscellaneous

From Thursday October 10, 2024, the UK has an additional new sanctions regulator following the official launch of the Office of Trade Sanctions Implementation (“OTSI”).  First announced in December 2023, its establishment was confirmed last month with the publication of The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations). 

An overview on new Russian sanctions and export controls issued by the European Union, focusing on anti-circumvention measures and the Russian financial, military, and LNG industries.

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