Cross-Jurisdictional Compliance

Navigating Divergent Sanctions Frameworks

Posted 6/6/25

The transatlantic sanctions alliance among the United States (U.S.), the United Kingdom (UK), and the European Union (EU) has demonstrated significant cohesion, particularly in response to Russia's invasion of Ukraine. However, critical divergences in implementation, scope, and enforcement complicate compliance for multinational entities.

As sanctions regimes evolve—often with extraterritorial implications—legal and compliance professionals must anticipate conflicts and establish adaptive, harmonized internal frameworks. This article analyzes these key differences and offers practical guidance for aligning compliance programs across jurisdictions.

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