Webcast: The New Era of Fluid Global Sanctions

October 21, 2015

​This 90 minute briefing provides an overview and assessment of recent substantial changes in key sanctions regimes and the upcoming divergence of US, EU and UN economic sanctions as Iran sanctions relief is implemented, the EU debates the renewal of sanctions against Russia and the US contemplates unilateral sanctions against cyber criminals and others.  This fluidity offers opportunities in some cases and also significant risk.  With continued global sanctions sensitivities, mounting penalties for sanctions violations, and conflicting sanctions compliance obligations in different countries, carefully navigating this new sanctions world will be critical.  This webcast, which includes two senior sanctions lawyers who were recently in the U.S. government and an EU government provides viewers an on-the-ground overview of what in-house counsel, compliance personnel, directors and senior executives should know about where sanctions have been, where they are going, and what this flux may mean.

Topics Discussed Include:

Sanctions Programs

Overview of Recent Economic Sanctions Developments and Near-Term Changes

  • Iran – Congressional (In)Action; Adoption Day, and Upcoming Implementation Day
    • Similarities and Divergence between EU and US Restrictions
  • Russia – Sectoral Sanctions; “Maintenance Actions”
    • January 2015 Divergence between EU and US Restrictions?
  • Cuba – What’s Left? What’s Next?
  • Cyber Sanctions – A Paper Tiger or Real Sanctions Authority?
  • Myanmar / Burma – Sanctions in the Wake of the Burmese Elections

Sanctions Programs

United States

  • Recent OFAC Matters and Focus
    • Evasion
    • Crimea Guidance
    • Recent Cases – Energy, Financial Services, Insurance
  • Enforcement Posture concerning Iran, Russia – More Listings? More Penalties?

European Union

  • Member State Activities
    • United Kingdom: Q1 2016 Launch of the Office of Financial Sanctions Implementation

Business Opportunities and Compliance Challenges

  • Global Compliance in an Era of Conflicting Sanctions Obligations

What’s Next? Trends to Watch

  • Further Iran/ Cuba Relief – Impact of the Presidential Election Season
  • Sectors to Watch:
    • Continued Focus on Financial Institutions
    • Enhanced Focus on Insurers, Tech, and Energy
  • Overlapping Risks and Enforcement – Sanctions + Anti-Money-Laundering + Corruption
  • Increasing Diversity of Enforcement Authorities – Local, Federal, Multilateral


Who should view this program:

In-house counsel, compliance officers, directors, senior executives, finance and audit staff, marketing executives and business development managers responsible for overseas business.

View Slides [PDF]


F. Joseph Warin – Chair of Gibson Dunn’s Washington, D.C. Office Litigation Department and Co-chair of the firm’s White Collar Defense and Investigations Practice Group.  Served as Assistant United States Attorney in Washington, D.C. from 1976-83.  In that capacity, he was awarded a Special Achievement award by the Attorney General.  As a prosecutor, he tried more than 50 jury trials. Areas of expertise include white collar crime and securities enforcement – including Foreign Corrupt Practices Act investigations, False Claims Act cases, special committee representations, compliance counseling and complex class action civil litigation.


Adam M. Smith – Of counsel in the Washington, D.C. office of Gibson, Dunn & Crutcher.  He is an experienced international lawyer with a focus on international trade compliance and white collar investigations, including with respect to federal and state economic sanctions enforcement, the Foreign Corrupt Practices Act, embargoes, and export controls. From 2010-2015 he served in the Obama Administration as the Senior Advisor to the Director of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and as the Director for Multilateral Affairs on the National Security Council.

Aleksi Pursiainen – Head of Trade Compliance at Nokia Corporation.  He advises Nokia’s senior leadership and other functions on legal and policy issues related to EU, US and UN sanctions, export controls and other regulations of international trade. Before joining Nokia Mr Pursiainen worked for several years in various legal roles within the Finnish Ministry for Foreign Affairs, most recently as the head of the Ministry’s sanctions team.

David A. Wolber – Associate in the Washington, DC office of Gibson, Dunn & Crutcher and a member of Gibson Dunn’s International Trade and White Collar Defense and Investigations Practice Groups. Primarily advises clients in the areas of international trade regulation, compliance and anti-corruption, with particular emphasis and experience assisting clients operating internationally who need to navigate the economic sanctions and embargo regulations administered by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC).