The International Comparative Legal Guide 2026

We are pleased to present the 2026 edition of ICLG - Sanctions. We hope that you will
find this year's edition informative.
As this edition is going to print, we can say without a doubt that 2025 has been a year
of tremendous change in the world of international trade and economic sanctions,
and we fully expect 2026 to continue apace.
In the Unites States, the second Trump Administration has brought about a sea
change in the rules and mechanics of global trade and finance, including the focus,
scope and use of sanctions - and counter-sanctions measures - by not only the United
States but also many other countries around the world.
In terms of trend lines, multilateralism appears to be waning. As the Russia-Ukraine
war continues into its fourth year, Europe re-arms, and the U.S. oscillates between
the threat of more sanctions or sanctions relief depending on whether a deal can be
struck, there is an open question as to whether, and to what extent, the United States,
United Kingdom, and European Union will continue to coordinate their Russiarelated
sanctions (see, for example, the already-splintered Russian oil price cap
mechanism). The United States' recent use of certain other sanctions, such as those
targeting International Criminal Court's judges and prosecutors, may also set it at
odds with some or many of its allies.
A potentially impending UN snapback of pre-JCPOA sanctions on Iran would serve
to bolster the Trump Administration's (re)declared "maximum pressure" strategy
targeting Iran's oil revenues, but could prove difficult to implement if Russia, China,
and historically nonaligned states such as India do not observe them.
We have also seen the novel use by the United States of tariffs across the board,
including as a means to threaten or even punish jurisdictions for activity which runs
counter to U.S. sanctions programmes or policies.
U.S. competition with China and the resulting U.S.-China trade war continues to
intensify, with sanctions playing a key role alongside many other tools including
tariffs, import and export controls, inbound and outbound investment controls, and
a growing panoply of other novel laws and regulatory regimes targeting U.S.-China
trade and investment flows. Meanwhile China is not sitting idle, and has continued
to flex its muscle through the increasing use of its various "counter-sanctions"
programmes to target primarily U.S. politicians and companies.
Finally, 2025 has seen a dramatic uptick in sanctions enforcement in other countries,
notably in the United Kingdom through the Office of Financial Sanctions
Implementation, and with the European Union picking up steam as well, particularly
in Germany.
Gibson, Dunn & Crutcher LLP is honored to join a group of industry-leading
colleagues in presenting the following chapters on sanctions across several different
jurisdictions. The following chapters are intended to provide a high-level overview of
sanctions worldwide and pursuant to each enumerated jurisdiction's national laws.
Readers are, of course, encouraged to contact Global Legal Group or the contributors
with further questions, comments, or observations.