November 2012 Sanctions Update: Sanctions-the Diplomatic Substitute for Military Action?

Analysis

Sanctions are a growing problem on the desk of every international trading business and bank. The introduction by the European Union (EU) of wide-ranging sanctions against Iran in 2010 signalled the start of a significant growth in compliance concerns. This year the US Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA) escalated those issues by widening the pool of affected parties and confirming a clear trend for governments to use sanctions as a foreign policy tool and the financial services sector as their enforcement arm.

To facilitate debate around the issues raised by international sanctions and to shed some light on current experience, Clyde & Co's commodities team held a seminar in London on 13 November 2012 attended by around 50 commodity producers, intermediaries, insurers and bankers.

Panellists at the debate, which was conducted under Chatham House rules, included Jonathan Marsh, Head of Legal at Vitol, Andy Wragg, Senior Manager, International Regulatory Affairs at Lloyd's and Clyde & Co's Clare Hatcher, Douglas Maag and Patrick Murphy.

This newsletter provides a brief summary of the discussion and the issues raised. The key topics covered included: