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).
- in Italy, publication of the decree imposing sanctions: Legislative Decree No. 109/2007 provides that in case of reiterated (i) violations of the prohibition of using/disposing of frozen assets or making, directly or indirectly, funds/resources available to designated persons, (ii) violations of the duties of reporting on the freezing of assets, (iii) any other violations of EU Regulations imposing restrictive measures or economic sanctions, the decree imposing penalties for the violation is published — for 5 years — on the website of the Minister of Economy and Finance or of the competent authority, indicating the name of those who committed the violation and the eventual legal proceedings in connection thereto;
- additional penalties set forth under AML regulations, where applicable (e.g. suspension of the business activity; publication of a statement mentioning the violation and who committed it; ban from managerial positions).