In addition to civil and criminal penalties, there may be additional collateral consequences of a sanctions violation.  These might include:

  • serious reputational damage;
  • in the US, contract bars or divestment by certain states that prohibit the state from contracting with or investing in companies that are doing business in certain countries, primarily Iran, even if that activity is not a violation under US law;
  • for UK solicitors, possible removal from the roll of the solicitors by the Solicitors Regulation Authority if the violation is deemed to breach the SRA Principles or SRA Handbook;
  • for UK regulated entities, a possible FCA investigation and/or enforcement action for a failure of systems and controls; and
  • in France, inter alia, the exclusion from public tenders for up to 5 years, or irrevocably (Article 131-39 of the French Criminal Code).

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