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Nikunj Agarwal

Associate in the Dispute Resolution Practice at the Mumbai office of Cyril Amarchand Mangaldas. Nikunj focuses on white-collar crimes, investigations, and disputes. He can be reached at nikunj.agarwal@cyrilshroff.com

Indirect Structures, Ownership Ties, and Regulatory Expectations: The Expanding Reach of Sanctions Compliance

Summary: With global regulators intensifying efforts to enforce sanctions, particularly concerning indirect or inadvertent breaches, Indian entities now face an elevated level of compliance risk — one that extends far beyond the scope of traditional list-screening methods. This article explores how OFAC’s evolving policies indicate that even providing indirect support or advisory services to

Beyond Strategic Autonomy: Is a Blocking Statue the Need of the Hour in the Age of Extraterritorial Sanctions

Summary: China’s recent invocation of its Blocking Rules against U.S. sanctions marks a significant moment in the evolving landscape of global sanctions law. As nations increasingly push back against the extraterritorial reach of unilateral sanctions, the question arises:  What does this mean for India? This article examines China’s move, its implications for the global sanctions regime, and what a potential Indian blocking statute could look like in practice.

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Sanctions Compliance Beyond the 50% Rule: A Practical Guide for Indian Businesses

Summary: The 50% ownership rule has always been the cornerstone of sanctions compliance offering apparent certainty to entities navigating complex cross-border transactions. However, in recent years, global regulators have started looking beyond the ownership percentage, scrutinizing effective control and influence to determine sanctions exposure. This piece examines the evolving sanctions landscape across the US, UK & EU and provides Indian businesses with a practical, risk-based compliance framework to align with international enforcement expectations.

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