Dame Europa or Uncle Sam?

UK-regulated firms with US ties are caught in a transAtlantic Catch-22 as they contend with conflicting sanctions regimes. By Christian Taylor and Richard Burger

Christian Taylor (christian.taylor@rpc.co.uk) is a trainee solicitor and Richard Burger (richard.burger@rpc.co.uk) a senior associate in Reynolds Porter Chamberlain’s regulatory and financial crime practice.

The UK’s regulatory relationship with the US has always been seen as one where when push actually comes to shove, the UK has been accused of passing over control in deference to its larger brother when conflicts arise. With the advent of the EU regulatory framework this deference appears to have been curbed, with EU wide regulations challenging US extra-judicial measures. However, what appears to be staunch opposition may not quite have the body to back up the bravado.