Economic Sanctions

A major aspect of US foreign policy involves economic sanctions imposed on specific countries, organizations, or individuals. This area of international economic regulation presents major compliance challenges to US companies operating in the global market. The Executive Branch, US Congress, and local governments are, with increasing frequency, imposing restrictions on US companies and US persons to prevent trade or financial transactions with targeted governments or entities.

Moreover, the regulatory risks associated with US embargo programs are increasing, as US companies are restricted from doing business with third-country entities and persons acting on behalf of a sanctioned government. Sanctions regulation involves a high degree of government discretion and unpublished interpretive guidance, further complicating compliance.

A hallmark of Steptoe's practice is advising corporate clients on the scope and subtleties of US sanctions regulations. With regard to embargoed countries, we have assisted clients with direct export, investment, and financial transactions, hiring of foreign nationals, third-party distributor relationships, joint ventures, mergers and acquisitions, licensing agreements, and parent-subsidiary relationships. Clients receive advice on the jurisdictional reach of sanctions regulations, the meaning of key regulatory terms, and the use of regulatory exceptions to achieve legitimate commercial or marketing objectives.

We have extensive knowledge of the regulations implementing each current sanctions program as well as those that have been in force during the last three decades. Our current and historical depth is central to advancing clients’ interests because the interpretation of each sanctions regime depends on the foreign policy context in which the embargo is formulated, as well as the accumulated experience of US regulators in administering embargo programs. We are very familiar with the statutory framework, Executive Orders, regulations and case law of the Trading With The Enemy Act, International Emergency Economic Powers Act, UN Participation Act, National Emergencies Act, the Anti-Terrorism and Effective Death Penalty Act, and various "specialty" statutes directed at sanctioned countries and entities.

Noteworthy

Chambers Global

Chambers Global, International Trade/WTO, Global Market Leaders (2008-2025)
Chambers Global, International Trade: Export Controls & Economic Sanctions, (The Elite), US (2019-2025)
Chambers Global, International Trade: Trade Remedies & Trade Policy, US (2020-2025)
Chambers Global, Disputes, International & Cross-Border Capabilities, US (2019-2025)
Chambers Global, International Trade: CFIUS Experts, US (2020-2025)
Chambers Global, International & Cross-Border Disputes (International Firms), China (2021-2025)
Chambers Global, International Trade/WTO (International Firms), China (2019-2025)
Chambers Global, International Trade/WTO, Asia-Pacific Region (2019-2025)
Chambers Global, International Trade/WTO, Europe-wide (2019-2025)

Chambers Asia-Pacific & Greater China Region

Chambers Greater China Region, Corporate Investigations/Anti-Corruption (International Firms) (2022-2024)
Chambers Greater China Region, International Trade/WTO (International Firms) (2022-2024)
Chambers Asia-Pacific, International Trade/WTO, Asia-Pacific Region (2009-2026)

Chambers Europe

Chambers Europe, International Trade/WTO, Europe/Belgium (2008-2023)

Chambers USA

Chambers USA, International Trade: CFIUS Experts, Nationwide (2017-2025)
Chambers USA, International Trade: Export Controls & Economic Sanctions: The Elite, Nationwide (2017-2025)
Chambers USA, International Trade: Trade Remedies & Trade Policy, Nationwide (2017-2025)
Chambers USA, International Trade, Nationwide (2005-2016)
Chambers USA, International Arbitration: Enforcement, Nationwide (2022)

Legal 500

Legal 500 Latin America, the International Firms: Compliance and Investigations (2026)
Legal 500 US, Government: Government Contracts (2024-2025)
Legal 500 US, International Trade: Trade Remedies & Trade Policy (2023-2025)
Legal 500 US, International Trade: Customs, Export Controls, & Economic Sanctions (2023-2025)
Legal 500 US, International Trade and National Security – CFIUS (2023-2025)
Legal 500 US, Dispute Resolution: International Trade (2007-2022, 2024)
Legal 500 US, Dispute Resolution: International Litigation (2025)
Legal 500 UK, Dispute Resolution: International Arbitration (2010-2025)
Legal 500 UK, Dispute Resolution: Public International Law (2010-2025)
Legal 500 EMEA, Customs, Trade, WTO & Anti-Dumping, Belgium (2011-2019, 2023)

Law360

Law360, International Trade Group of the Year (2010-2013, 2015, 2019)

Global Arbitration Review

Global Arbitration Review, "International arbitration practice that impressed in the past year," (2016)
Global Arbitration Review, GAR 100 (2017-2023)

Global Investigations Review

Global Investigations Review (GIR) 100, Top 30 Firms for Investigations Worldwide (2015-2024)

WorldECR

WorldECR, Sanctions Law Firm of the Year, USA (2018, 2021), Sanctions Highly Commended Law Firm, USA (2017);
WorldECR, Export Controls, Law Firm of the Year, USA (2015-2016), Highly Commended Law Firm, USA (2017), Runner-Up Law Firm of the Year, USA (2018)
WorldECR, Sanctions Law Firm of the Year Runner-Up, Rest of the World (2021)

Asia Legal Business

ALB China Awards, International Firm of the Year: International Trade (Award in 2021, Shortlisted in 2022-2024)
ALB China Awards, Regulatory Compliance Law Firm of the Year (Shortlisted 2022-2024)
ALB Hong Kong Awards, Regulation and Investigations Law Firm of the Year (Shortlisted 2020-2021, 2023)
ALB Japan Awards, Japan Practice Foreign Law Firm of the Year (Award in 2021, Shortlisted in 2023-2024)
ALB Korea Awards, Korea Practice Foreign Law Firm of the Year (2022-2023)

China Business Law Journal

China Business Law Award, International Trade (2013-2025)
China Business Law Award, Corporate Compliance (2019-2025)
China Business Law Award, Government and public policy (2022)
China Business Law Award, Anti-Bribery & Compliance (2015, 2018)

China Law & Practice

China Law & Practice, International Firm of the Year: Dispute Resolution, Honorable Mention (2024)
China Law & Practice, International Firm of the Year: Trade Award (2016, 2018-2020, 2022); Shortlisted (2021)
China Law & Practice, Shortlisted, International Firm of the Year: Regulatory & Compliance (2018, 2021-2022)

Depending on the country involved, US economic sanctions can permit some activity with an embargoed country. For example, foreign subsidiaries of US companies may be able to transact business with a country subject to US embargo restrictions; however, the foreign subsidiary cannot involve US nationals, lawful residents, or its US parent, and the business opportunity cannot be referred to the subsidiary by the parent. A US company may be able to supply goods to a third-country company, even though that company may be using those goods for commercial activities in the embargoed country.

At the same time, US companies and US persons (even those employed abroad) must be wary of the regulatory pitfalls leading to corporate or personal exposure to enforcement proceedings.

The US government maintains a lengthy list of "Specially Designated Nationals," with whom US persons cannot do business. Many of the individuals and entities on this list are located in countries enjoying good relations with the United States. The US government also has developed expansive, yet informal, interpretations of the embargo prohibitions, many of which are not obvious from the regulatory language.

Steptoe has developed internal compliance advice and mechanisms for clients attempting to navigate the shoals of US economic sanctions. We work closely with in-house counsel and key management personnel to understand the nature of a company's operations, its products and services, and its internal structure, to ensure that corporate compliance is thorough, yet not unnecessarily restrictive. We have extensive experience in tailoring compliance manuals and SOPs to accommodate decentralized organizations.

Steptoe lawyers have a close familiarity with the Office of Foreign Assets Control (OFAC), which administers US embargo programs. We identify situations when advisory opinions or specific licenses from OFAC are needed, and then seek the authorization necessary to move forward with a proposed transaction.

OFAC actively initiates investigations and brings administrative enforcement actions for transgressions of US economic sanctions. Steptoe has extensive experience in handling investigation and enforcement proceedings, including routine information requests, pre-penalty contacts, negotiated settlements, and administrative proceedings arising from penalty actions.

We also have handled voluntary disclosures to the US government on terms that are favorable to our clients. Where appropriate, Steptoe uses its white-collar enforcement capability to supplement its sanctions experience in dealing with US government prosecutors.

Our experience in the area of economic sanctions includes:

In-depth knowledge of the regulatory prohibitions applicable to countries sanctioned by the United States, the European Union, the United Kingdom, Japan, or the United Nations
Jurisdictional issues in the administration of US economic sanctions, including extraterritorial aspects of export, reexport, investment, and transactional controls
Formulation of compliance programs for multinational corporations and organizations with multiple levels of US management
Structuring transactions to permit commercial activity consistent with regulatory compliance
Advisory opinions, interpretations, license applications, and knowledge of regulatory exceptions and limitations
Negotiation, voluntary disclosures, and defense of enforcement proceedings
Familiarity with US regulatory institutions and the interagency policy-making and licensing process

Our clients span a wide spectrum of US industries, and include multinational corporations, small to mid-sized businesses, partnerships, trade associations, and individuals. A sampling of the industries we represent is as follows:

Hydrocarbon exploration and production
Refining
Chemicals
Construction
Engineering
Food and beverages
Mechanical and industrial equipment
Financial services
Software
Telecommunications and data transmission
Legal
Data processing
Airline services
Electronics

Professionals

Evan T. Abrams

Evan Abrams counsels financial institutions, multinational corporations, and individuals on a variety of international regulatory and compliance matters. He regularly advises clients on issues related...

Partner

Anti-Money Laundering, Economic Sanctions, Financial Services, Artificial Intelligence

Washington, DC
+1 202 429 3052

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Andrew C. Adams

Andrew Adams, a New York partner, advises companies and individuals in the areas of government and internal investigations, corporate governance, and white collar and regulatory matters. His practice...

Partner

Blockchain & Cryptocurrency, Financial Services, Financial Regulatory Compliance & Policy, White-Collar Defense

New York
+1 212 957 3081

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Ana Amador

Ana Amador is an international trade and regulatory compliance lawyer dually based in New York and Brussels. She advises sovereign governments, multinational corporations, and industry groups on...

Associate

Antitrust/Competition, Economic Sanctions, Export Controls, EU Trade

New York
+1 212 378 7620

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Nicole Arellano-Brillembourg

Nicole Arellano-Brillembourg focuses her practice on international trade matters, including antidumping (AD) and countervailing duty (CVD) proceedings before the US Department of Commerce (DOC) and...

Associate

Trade Remedies, Trade Policy & Negotiations, Customs, Economic Sanctions

Washington, DC
+1 202 429 3035

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Alexandra Baj

Alexandra Baj heads Steptoe's International Trade and Regulatory Compliance group. She advises on export controls and economic sanctions laws and regulations, anti-corruption investigations and...

Partner

Export Controls, Economic Sanctions, Trade Remedies, Trade Policy & Negotiations

Washington, DC
+1 202 429 6478

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Sophia Breggia

Sophia Breggia counsels clients on a range of regulatory and enforcement matters, primarily in the financial services sector, including those before the Department of Justice (DOJ), the Securities and...

Associate

Financial Innovation & Regulation, Independent & Internal Investigations, Blockchain & Cryptocurrency, Financial Regulatory Compliance & Policy

Washington, DC
+1 202 429 3028

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Ali Burney

Ali Burney's practice focuses on representing clients in the Asia-Pacific region on matters related to US national security laws (incl. US economic sanctions and export controls), the US Foreign...

Partner

Economic Sanctions, Export Controls, Anti-Corruption/FCPA, Anti-Money Laundering

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Philip Capers

Philip Capers focuses his practice on assisting clients with international regulatory compliance issues, including laws, policies, and regulations administered by the US Office of Foreign Assets...

Associate

Economic Sanctions, National Security & Cross-Border Transactions, Export Controls

Washington, DC
+1 202 429 3912

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Timothy L. Dickinson

Timothy L. Dickinson is a Senior Counsel in the firm's Washington, DC office, with more than 40 years of experience in anti-corruption law. His practice encompasses a wide range of areas, including...

Senior Counsel

Anti-Corruption/FCPA, Export Controls, Economic Sanctions, Independent & Internal Investigations

Washington, DC
+1 202 429 8028

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Brian J. Fleming

Brian Fleming is a deputy chair of Steptoe's International Trade and Regulatory Compliance group. He focuses his practice on matters at the intersection of national security and international trade,...

Partner

National Security & Cross-Border Transactions, Economic Sanctions, Export Controls, Independent & Internal Investigations