--- title: "International Sanctions and Export Controls" id: "2056" type: "expertise" slug: "international-sanctions-and-export-controls" published_at: "2026-01-26T10:48:40+00:00" modified_at: "2026-07-29T10:33:00+00:00" url: "https://www.august-debouzy.com/en/expertise/international-sanctions-and-export-controls/" markdown_url: "https://www.august-debouzy.com/en/expertise/international-sanctions-and-export-controls.md" excerpt: "Compliance, Risk, and Disputes Sanctions and export control work is no longer solely a compliance discipline. Enforcement is intensifying across all major jurisdictions, and companies now face administrative and criminal proceedings before French or foreign regulators when a violation is..." taxonomy_language: - "English" taxonomy_post_translations: - "pll_69774688099f6" taxonomy_tax_expertise: - "International Sanctions and Export Controls" taxonomy_tax_famille_expertise: - "Regulatory" --- ## Compliance, Risk, and Disputes Sanctions and export control work is no longer solely a compliance discipline. Enforcement is intensifying across all major jurisdictions, and companies now face administrative and criminal proceedings before French or foreign regulators when a violation is alleged or suspected. Our team handles both upstream compliance and downstream enforcement. We advise on compliance program design, risk mapping, due diligence, internal investigations, and sanctions issues in M&A transactions. Where most practices focus on screening and policy design, we regularly act as counsel in contentious proceedings arising from actual or suspected breaches: customs disputes, enforcement actions, and cross-border investigations. We represent clients before the French Treasury (DGT), the Dual-Use Goods Authorities (SBDU and ANSSI), customs authorities (DNRED), and competent courts, in high-stakes matters where regulatory and criminal dimensions overlap. Our multijurisdictional experience enables us to coordinate defense strategies across UN, EU, U.S., and U.K. regimes, with partner firms in over 120 countries. ## *our*Capabilities ### (01) International Sanctions We assist clients across the full sanctions lifecycle, with particular depth in managing enforcement situations and contentious proceedings. This includes compliance with EU, U.S., U.K., and UN sanctions regimes, risk mapping and internal policies, asset freeze and restrictive measures, licensing and exemption requests, internal investigations and remediation. We regularly represent clients before competent authorities in sanctions-related enforcement proceedings, combining regulatory expertise with contentious defense capabilities. ### (02) Export Controls We advise on export control regulations applicable to controlled goods, technologies, and sensitive transfers, and act as counsel when those regulations give rise to disputes or enforcement actions. Our work covers classification of goods and technologies, export licensing and authorizations, compliance programs and internal procedures, customs controls and inspections. We represent clients in customs disputes and enforcement proceedings before the competent authorities, ensuring both regulatory compliance and effective defense strategies. Collective excellence at the service of the *highest standards.* Team [Olivier Attias ( Partner )](https://www.august-debouzy.com/en/collaborateur/olivier-attias/) [Dahlia Brazi ( Associate )](https://www.august-debouzy.com/en/collaborateur/dahlia-brazi/) [Noureen Nhari ( Associate )](https://www.august-debouzy.com/en/collaborateur/noureen-nhari/) [Sophie Peter ( Associate )](https://www.august-debouzy.com/en/collaborateur/sophie-peter/) Précédent Suivant ## Contact Us ## *our*References International Sanctions and Export Controls #### French Energy Group – Export Control Compliance Program Advice to a leading French energy group on establishing and strengthening internal compliance procedures concerning export controls and international sanctions. International Sanctions and Export Controls #### Technology Company – Export Control Regulations Advice to a technology company on analyzing export control laws and restrictions under international sanctions frameworks. International Sanctions and Export Controls #### Global Chemical Leader – Sanctions Compliance Advice to a global leader in the chemical sector and its subsidiaries in navigating international sanctions regimes issued by the European Union, Switzerland, and various national authorities, as they relate to ongoing business operations. ## *FAQ* ### (01) How should you implement an international economic sanctions compliance program? Economic sanctions (asset freezes, sectoral restrictions, import and export prohibitions) flow simultaneously from multiple authorities: the European Union, the United Nations, the United States (OFAC), the United Kingdom (OFSI) and other jurisdictions. Since Directive (EU) 2024/1226, transposed into French law, violation of European sanctions can constitute a criminal offence. We help companies design and deploy sanctions compliance programs tailored to their geographical and sectoral exposure: risk mapping, counterparty and transaction screening procedures, team training, alert management and escalation procedures. We also provide continuous regulatory monitoring of sanctions regime developments. ### (02) How should French companies manage the risk of US extraterritorial sanctions (OFAC)? US extraterritorial sanctions (OFAC, OFSI) can reach French companies even without a direct territorial connection to the United States, where a transaction involves a US dollar, a US entity or US infrastructure. The French blocking statute (1968 Act as amended) generally prohibits communicating certain information to foreign authorities, creating a difficult regulatory conflict. We assist companies in assessing their exposure to secondary sanctions, implementing appropriate screening procedures and, in cases of potential violation, structuring voluntary self-disclosure approaches before the competent authorities. ### (03) What obligations govern export controls on dual-use goods and defence products? Regulation (EU) 2021/821 on dual-use goods, applicable since 9 September 2021, requires exporters to obtain prior authorization for exports of goods capable of civilian and military application. In France, export controls on war materials and related items are governed by Articles L. 2335-1 et seq. of the Defence Code. These obligations also cover brokering, technical assistance and intangible technology transfers. We assist exporters in obtaining licences, classifying goods, managing compliance programs and responding to inspections by the competent authorities (SBDU, DGA). ### (04) How can you integrate new economic security requirements and foreign investment screening (FDI) into your strategy? National economic security imposes growing constraints on foreign investment in sensitive sectors. Decree No. 2019-1590 of 31 December 2019 expanded the scope of foreign investment screening in France (IEF) to new sectors (artificial intelligence, robotics, cybersecurity, biotechnology, energy). In parallel, Regulation (EU) 2019/452 establishes a European cooperation framework between member states for screening foreign direct investments. We advise foreign investors and French targets on qualifying transactions subject to prior authorization, preparing authorization request files and engaging with the Directorate General of the Treasury. ### (05) Why choose August Debouzy as your law firm for international sanctions and export controls? Industrial groups, defence companies, financial institutions, investment funds and technology companies entrust us with securing their international operations in an increasingly constrained geopolitical environment. We cover the full spectrum: compliance with European, US and UN sanctions, export controls on dual-use goods and war materials, foreign investment screening, self-disclosure and defence in authority investigations. Our team coordinates legal, regulatory and strategic dimensions to enable our clients to operate safely on international markets.