The imposition of targeted sanctions presents an array of challenges for businesses and individuals made subject to them.
The primary focus when sanctions are imposed is usually to have them lifted as quickly as possible. Which avenues of challenge are available depends upon which entity has imposed them –the UN, the EU or an individual State. At the UN it may, subject to which sanctions regime applies, be possible to make a delisting application to the UN Ombudsperson. In the EU and domestically, it may be possible to seek judicial review of the relevant administrative decision. More informal negotiations with the authorities can also be effective.
Once sanctions have been lifted, it is not, unfortunately, always business as usual since new problems often arise. Our clients have found that they have difficulty in persuading banks to deal with them or their money, and this can make it difficult, if not impossible, to rebuild businesses and lives which were put on hold whilst sanctions applied. Further, the reputation of the previously sanctioned business or individual is often left in tatters. However, there are various practical steps which can be taken to rebuild reputations following the removal of sanctions.