Why Strategic Coordination Is Crucial When Sanctions Risk Crosses Borders
In a world of interconnected finance and geopolitics, sanctions rarely operate in isolation. When individuals or companies are sanctioned by one jurisdiction, be it the UK, US, EU, or others, the repercussions often ripple across continents. A person designated by OFAC in the US may suddenly find their accounts frozen in Switzerland, assets scrutinised in London, and legal relationships unravelled in Dubai or Singapore.
This globalised effect demands a coordinated legal response. But too often, clients facing sanctions exposure rush to engage multiple law firms independently, each offering jurisdiction-specific advice without a unified strategy. The result? Conflicting recommendations, disjointed timelines, inconsistent messaging to regulators and banks, and delayed resolutions.
This article explores how sanctioned individuals, family offices, and multinational businesses can, and must, approach global sanctions enforcement with a unified legal strategy. Drawing on real examples and best practices, we explore what effective coordination looks like, and how Linkilaw Solicitors positions itself as a legal strategy hub to navigate these complex cases.
1. The Global Nature of Sanctions Risk
Sanctions regimes are territorial in origin, but global in effect. A designation by:
- OFSI (UK) restricts access to UK-based assets and financial services.
- OFAC (US) may block any transaction that touches US dollars or involves US persons, even abroad.
- The EU Council affects asset freezes, travel bans, and economic activity throughout EU member states.
Other regimes such as SECO (Switzerland), Canada’s SEMA, Australia’s DFAT, or UAE’s Cabinet Resolution 74 also add further complexity.
For globally active individuals or institutions, this means that even if the legal risk originates in one place, the compliance consequences span many. A sanctioned Russian national may face blocked payments from an EU counterparty, while their BVI trustee panics over reputational risk and a UAE bank flags their account for enhanced due diligence.
Sanctions touch everything: banking, trusts, crypto wallets, legal representation, asset sales, even ongoing litigation. The issue isn’t just legal – it’s operational, reputational, and deeply strategic.
2. The Pitfalls of Fragmented Legal Advice
In high-pressure scenarios, clients often react by hiring multiple lawyers, one in each jurisdiction affected. While this seems prudent, it often creates new problems such as:
- Conflicting legal opinions: One lawyer advises full disclosure, another urges silence. Who’s right? Without central strategy, no one is accountable for the big picture.
- Duplicated work and costs: Each law firm redoes the same background checks, drafts overlapping documents, and makes uncoordinated outreach to banks or regulators.
- Timeline confusion: Delays arise when lawyers wait for direction from other jurisdictions, or worse, act without alignment.
- Inconsistent narrative: This is the most dangerous. If one firm tells OFSI that funds are frozen, and another tells a UAE bank that assets remain accessible, credibility collapses.
In a sanctions case, reputation is everything. Inconsistent or piecemeal legal communications can lead banks to de-risk clients, trigger asset seizures, or stall licence applications.
3. Why a Legal Strategy Hub is Essential
To avoid these outcomes, clients need a legal strategy hub. This is a central point of coordination where legal, reputational, and strategic decisions are made in the best interests of the client.
This hub:
- Defines the overarching objectives: Is the goal to release assets? Fund litigation? Secure licences? Protect reputation?
- Coordinates the legal workstream: Aligning tasks, deadlines, and communications across all counsel.
- Maintains a unified voice: Regulators, counterparties, and financial institutions hear a single, consistent story.
- Adapts in real time: If OFAC issues new guidance or OFSI tightens licence criteria, the strategy adjusts across jurisdictions immediately.
Linkilaw Solicitors approach is to lead as strategic counsel and not just as legal implementers. We oversee local counsel, integrate forensic experts, and communicate with regulators as part of a holistic response. In sanctions cases, leadership and clarity are non-negotiable.
4. Best Practices for Managing Multi-Jurisdiction Sanctions Counsel
From our experience, here are the critical success factors:
1. Appoint a Clear Strategic Lead
Someone (ideally one law firm) must own the legal strategy. This firm should have cross-border experience and be empowered to manage all counsel and advisors.
2. Clarify Scope for Each Jurisdiction
Each local lawyer should know exactly what they are handling. Avoid overlap. Avoid gaps. This clarity prevents territorialism and confusion.
3. Use Secure Shared Platforms
Shared data rooms or encrypted collaboration tools reduce delays and avoid email chaos. Everyone sees the same information in real time.
4. Align Messaging
If multiple jurisdictions are submitting licence applications or regulatory responses, all facts and representations must align. Even small inconsistencies can cause applications to fail or raise suspicion.
5. Centralise Communication Logs
Track all regulatory correspondence, bank outreach, and counterparty communications in a single record. This avoids repetition and maintains coherence.
6. Prepare Contingency Plans
What if a new designation is issued? A bank account is closed suddenly? Assets are moved? Preparedness avoids panic.
5. Case Examples: Strategy vs. Fragmentation
Let’s compare two real-world scenarios:
Case A: Strategic Success
A Middle Eastern family office faced asset freezes after one principal was designated by OFAC. Linkilaw Solicitors led the legal strategy, coordinating with firms in London, Dubai, and Zurich. Within days, we submitted OFSI and OFAC licence applications, triggered strategic disclosures to pre-empt account closures, and isolated risk-bearing entities.
Result: core operations continued, licences were granted, and no reputational leaks occurred.
Case B: Fragmented Failure
A sanctioned businessperson hired separate law firms in the US, UK, and Cyprus – none of whom communicated. OFAC was informed of one structure, while UK banks were told another. Conflicting statements caused all banks to suspend accounts pending clarification. Months later, no licences had been granted and multiple law firms had fired the client over inconsistent instructions.
Lesson: in sanctions cases, disorganisation is more dangerous than ignorance.
6. How Linkilaw Solicitors Coordinates Cross-Border Sanctions Cases
At Linkilaw Solicitors, we don’t just “advise” on sanctions. We lead global strategy for sanctioned clients, family offices, trustees, and regulated professionals.
Our model includes:
- Project management of all global legal counsel, timelines, and deliverables.
- Preparation of licence applications (OFSI, OFAC, EU) including evidence, banking communications, and regulator engagement.
- Reputation-sensitive strategy, ensuring that responses protect our client’s public and private standing.
- Integrated teams with banking experts, investigators, and offshore counsel who operate as one.
We treat sanctions like surgery: high-stakes, precision-driven, and coordinated from a single operating room.
Conclusion: Don’t Just Hire Lawyers, Please Hire Strategy
When sanctions strike, the reflex is to hire top lawyers in every affected country. But unless someone connects the dots, this often causes more chaos than clarity.
The real risk in sanctions cases is not just legal, it’s strategic. That’s why you need a central legal strategy hub. You need orchestration, discipline, and foresight.
At Linkilaw Solicitors, we offer precisely that. We don’t just act. We lead.
