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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

Sanctions by Formula: What the Graham Act Means for India’s Trade and Businesses

Summary: The US Senate has passed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which proposes to impose up to 100% secondary tariffs on countries importing significant volumes of Russian crude oil or natural gas, affecting all sectors regardless of goods. As one of the largest purchasers of Russian energy, India faces a significant risk of triggering this mechanism. This article examines the framework of the proposed legislation, its likely commercial impact on Indian trade, and the contractual and policy measures that Indian businesses must now consider.

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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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