Sanctions

Designations are imposed at pace, often on the basis of intelligence assessments that are not disclosed to those affected, and across multiple jurisdictions simultaneously. The consequences — frozen assets, blocked transactions, reputational damage and effective exclusion from the international financial system — can be immediate and severe.

Amadeus advises individuals and entities navigating the full range of sanctions-related challenges, from the moment of designation through to delisting and the restoration of normal commercial life.

Designated Persons

Being listed as a Specially Designated National by OFAC, designated under the UK Sanctions List, or subject to EU restrictive measures is not a criminal conviction, but its practical consequences can be more immediate. Assets are frozen, counterparties disengage and the ability to conduct ordinary financial life is suspended without notice or prior hearing.

We advise designated individuals and entities on the full range of responses available to them: the factual basis for the designation, the evidentiary record underpinning it and the procedural mechanisms for seeking review. Each challenge begins with a structured internal review of the publicly stated grounds, any disclosed evidence, and the political and regulatory context in which the designation was made. Where grounds for challenge exist, we prepare a comprehensive submission addressed to the relevant authority, marshalling factual, legal and contextual arguments the process requires.

Transaction Advice

Sanctions regimes are not limited to their listed targets. They extend to those who deal with designated persons, process their funds, or participate in transactions that engage the prohibitions, directly or indirectly. The exposure can arise from correspondent banking relationships, corporate ownership structures, contractual counterparties, or supply chain arrangements that are not immediately visible at the point of transaction.

We advise companies, financial institutions and private clients on the sanctions exposure arising from specific transactions and commercial relationships, including assessments of ownership and control, the application of primary and secondary sanctions, and the scope of available licences and general permissions. Where a transaction is time-sensitive, we provide clear, practical advice on the risks and on steps that can be taken to mitigate them.

Compliance Frameworks

For businesses operating across sanctions-sensitive jurisdictions, reactive advice is insufficient. We assist clients in understanding their obligations under the applicable regimes and in developing the internal procedures necessary to meet them, including screening protocols, due diligence frameworks and licence management. This work draws on our direct experience of how regulators approach compliance failures in practice.

Licence Applications

Sanctions regimes provide for licences (issued by OFAC, OFSI, or the competent EU authority) that permit otherwise prohibited activity in defined circumstances. We advise on whether a licence application is available and viable, and prepare the submissions required to support it.

Contribution to International Policy

Amadeus regularly contributes to the work of the United Nations Special Rapporteur on the Negative Impact of Unilateral Coercive Measures on the Enjoyment of Human Rights. Unilateral sanctions, whilst a legitimate instrument of foreign policy, can produce effects that extend well beyond their stated targets, bearing disproportionately on civilian populations, humanitarian actors and individuals who have no meaningful means of challenging the basis for their designation. Our engagement with the Special Rapporteur's mandate reflects our view that effective sanctions policy must be accompanied by robust accountability mechanisms and genuine access to remedy.