Ursula von der Leyen, the new president of the European Commission, has called for ‘new proposals to ensure Europe is more resilient to extraterritorial sanctions by third countries and to ensure that the sanctions imposed by the EU are properly enforced…throughout its financial system.’ See September 2019 Mission Letter from President von der Leyen to Valdis Dombrovskis, Executive Vice-President responsible for the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (FISMA). A portfolio-allocation document published early December 2019 confirms that responsibility for sanctions has formally been moved from the EU’s Foreign Policy Instrument Service (FPI) to FISMA.

FISMA’s work includes:

  1. Presenting new policy initiatives to ensure that financial markets are well-regulated and supervised;
  2. Monitoring financial-sector developments and structures in the Member States and ensuring satisfactory implementation of EU legislation at the national level; and
  3. Working closely with international partners to promote consistent regulation and the implementation of agreed standards and principles around the world.

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Photo of Erik de Bie Erik de Bie

Erik de Bie is an attorney-at-law focused on international trade, customs and VAT matters. Erik counsels clients in European trade, export control, sanctions, customs, VAT and excise duty related matters, including litigation. He concentrates his practice on developing and implementing European savings programs,

Erik de Bie is an attorney-at-law focused on international trade, customs and VAT matters. Erik counsels clients in European trade, export control, sanctions, customs, VAT and excise duty related matters, including litigation. He concentrates his practice on developing and implementing European savings programs, setting up and restructuring European distribution and supply chains, improving and structuring customs, excise duty and VAT related compliance, and limiting risks and liabilities. Given the developments in European legislation and the needs of his clients, Erik is frequently involved in cross-border matters, including obtaining certification as Authorized Economic Operator (AEO), implementing customs bonded warehouse regimes and counseling on VAT issues.

Erik represented (and represents) many companies before Dutch Tax and Customs Courts, the Dutch Supreme Court, the European Commission, and the European Court of Justice.

Photo of Kara M. Bombach Kara M. Bombach

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention),

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Russia), entities and individuals. Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense. Kara has deep experience representing individuals and entities before OFAC in delisting matters and challenges to OFAC sanctions designations.

She has deep experience advising national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anticorruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.