An analysis of sanctions enforcement shows shows results that may be surprising to many people. The United States has sanctioned over fifty individuals and companies based in Singapore. In the finance industry, in particular, the highest ever sanctions penalties have been paid by organisations that, firstly, operate in the banking sector and, secondly, are headquartered outside of the United States and – in some cases – have no presence at all in the United States.
Sanctions and sanctions compliance is not, then, an issue only for certain countries or individuals. They are applicable to every business and everyone, and this is an area of law that is only going to expand further as the “weapon of choice” in international conflicts.
Jonathan Goacher is a partner at Stephenson Harwood, a London-headquartered law firm. He is based in Singapore, and has now lived here for 7 years. Originally from the UK, he is also admitted to practise law in the State of New York. He is one of a small number of sanctions experts based in Asia, having spent many years advising, presenting and training on sanctions across the world. He was naturally drawn to sanctions work, after studying both law and politics for his undergraduate degree.
Jonathan is regularly asked to advise various high-profile international businesses on US and other economic sanctions, especially those administered and enforced by the Office of Foreign Assets Control (OFAC). His work includes advising clients on deals and trades that are potentially affected by sanctions; obtaining specific licences from sanctions regulators in order to permit actions that would otherwise be prevented by sanctions; and has represented sanctioned individuals in delisting applications.
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