Gibson Dunn Lawyers Author NGO Sanctions Chapter of GIR’s Guide to Sanctions

Article  |  July 11, 2025

Global Investigations Review


Partners Adam Smith and David Wolber, along with associates Dharak Bhavsar and Anna Searcey, are the co-authors of a chapter in the latest edition of The Guide to Sanctions from Global Investigations Review.

Their chapter, “Sanctions Considerations for Non-Governmental Organisations in a New U.S. Administration,” offers an overview of key prohibitions affecting NGOs and analyzes their impact. The authors also highlight emerging trends, provide practical compliance guidance, and examine efforts to tailor sanctions in ways that minimize harm to humanitarian operations.

This chapter was first published in Global Investigations Review in June 2025. For further in-depth analysis, please visit GIR The Guide to Sanctions – Edition 6.