The rise of network sanctions

Trudie Protopapas, of Hill Dickinson, explores the next frontier of EU, UK and US sanction enforcement

For much of the modern sanctions era, enforcement was primarily focused on targeting individuals, state-owned entities, restricted sectors of an economy, or specific prohibited transactions or trades. Sanctions compliance programmes were therefore largely geared to identifying sanctioned persons or entities involved in a trade or transaction and preventing dealings with them. The central question was, therefore, whether a particular person or entity fell within the scope of a sanction's prohibition.