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Proceed with caution: Lifting or partial relaxation of sanctions brings opportunities and risks

The lifting or partial relaxation of sanctions can offer great opportunities for business, but careful consideration of the remaining controls and enforcement risk is essential.

In their article “Lifting Sanctions under EU and US Law” in WorldECR, Daniel Lawrence, Stephanie Brown Cripps and Maziar Jamnejad discuss the legal mechanisms and processes for lifting or relaxing sanctions, provide recent examples of EU and US sanctions regimes that have been eased or lifted, consider enforcement risk during the period that the political relationship with the targeted state is improving, address ongoing risk where sanctions may be re-imposed or “snap back,” and provide possible approaches when sanctions are proposed only to be partially lifted, including a summary of the legal rules surrounding the extent to which EU and US persons may be allowed to engage with sanctioned countries or persons ahead of formal lifting.