On 23 April 2026, the Council of the European Union adopted a new package of economic sanctions against Russia, marking the twentieth sanctions package introduced since the start of Russia’s full scale invasion of Ukraine.

Click here to read the full alert on cov.com.

Photo of David Lorello David Lorello

David Lorello is a partner in the firm’s London office and serves as a vice chair of the firm’s International Trade Controls Practice Group. David advises clients concerning a range of international regulatory, white collar, and commercial matters under both European and U.S.

David Lorello is a partner in the firm’s London office and serves as a vice chair of the firm’s International Trade Controls Practice Group. David advises clients concerning a range of international regulatory, white collar, and commercial matters under both European and U.S. laws. 

David is recognized in the leading peer review publications for his work on trade controls and anti-corruption compliance and investigations matters, with Chambers Global describing David as a “compliance authority” in those areas. He appeared as an expert commentator at the UK Parliament’s Select Committee’s inquiry into UK Arms Exports. David, alongside other experts, spoke about the potential impact of the UK’s withdrawal from the EU on strategic export controls and sanctions policies.

Anti-Corruption Compliance and Investigations

David regularly assists clients in investigating anti-corruption compliance issues arising under the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and other related U.S., UK, and European anti-bribery and anti-money laundering laws. David has particular experience in managing corporate investigations and developing anti-corruption compliance programs for companies operating in Europe, including coordinating advice concerning parallel risks under U.S. and European anti-corruption laws, advising clients concerning European criminal enforcement and debarment risks, and ensuring compliance with European data protection and workplace laws in the course of investigations and compliance matters.

David also regularly represents clients before the World Bank, and other international financial institutions, in debarment proceedings concerning allegations of corrupt practices in connection with contracts financed by those institutions. In addition, David advises clients concerning the commercial liability risks arising from corrupt practices, including private rights of action that may arise for parties that suffer losses as a result of corrupt practices.

Export Controls and Economic Sanctions

David regularly represents clients before the major agencies responsible for export controls and economic sanctions laws and regulations, both in the United States and European Union. He has assisted clients in export and sanctions licensing and compliance issues with regard to a variety of industries and products, including encryption and other computer technologies, satellites, oil and gas products, military items, and other goods and technology controlled for export due to national security reasons. David has extensive experience assisting clients in developing effective export compliance strategies, including preparing export license requests, voluntary self-disclosures and intra-company agreements as well as policies necessary to ensure export controls and economic sanctions compliance.

David has particular experience in assisting clients in economic sanctions matters relating to the financial services industry. He has represented financial services clients in various matters before U.S. and EU Member State regulators, and he has worked with financial services clients in developing tailored internal controls focused on economic sanctions compliance.

Photo of Emanuel Ghebregergis Emanuel Ghebregergis

Emanuel Ghebregergis advises clients on international trade controls, foreign direct investment (FDI), environmental, social, and governance (ESG), and litigation matters under European and German laws.

In his international trade controls practice, Emanuel counsels multinational companies across various sectors, including the life sciences, energy…

Emanuel Ghebregergis advises clients on international trade controls, foreign direct investment (FDI), environmental, social, and governance (ESG), and litigation matters under European and German laws.

In his international trade controls practice, Emanuel counsels multinational companies across various sectors, including the life sciences, energy, and defense sectors on EU and UK economic sanctions and export controls requirements. He has extensive experience with major sanctions regimes involving Russia, Belarus, Iran, Syria, and Myanmar, as well as national-security–related export controls on dual-use and military goods. Emanuel regularly assists clients with export and sanctions licensing matters before BAFA and other EU Member State authorities and supports corporate and private equity clients in M&A transactions, including sanctions and export-controls due diligence, transaction risk assessments, and post-acquisition compliance integration.

Emanuel also advises on German foreign investment rules and works closely with cross-border deal teams to navigate German investment review processes. Emanuel also counsels companies on obligations under the German Supply Chain Due Diligence Act (LkSG), the Energy Efficiency Act, and other emerging EU-level sustainability and due-diligence frameworks. He also represents clients in German commercial and administrative litigation matters.

Photo of Sarah Bishop Sarah Bishop

Sarah Bishop is a U.S. and UK-qualified lawyer who advises companies on ethics and compliance programs, compliance with anti-corruption and anti-money laundering laws, business and human rights (BHR), white collar investigations, and suspension and debarment.

Sarah’s compliance advisory practice includes helping multinational corporations…

Sarah Bishop is a U.S. and UK-qualified lawyer who advises companies on ethics and compliance programs, compliance with anti-corruption and anti-money laundering laws, business and human rights (BHR), white collar investigations, and suspension and debarment.

Sarah’s compliance advisory practice includes helping multinational corporations develop and test the robustness of ethics and compliance programs, conducting risk assessments, conducting transactional and third party due diligence, supporting post-acquisition compliance integration projects, and delivering compliance training. She has particular expertise advising on the U.S. Foreign Corrupt Practices Act (FCPA) and UK Bribery Act and has advised companies in the energy, mining, pharmaceutical, healthcare, technology, and consumer goods sectors, among others, on anti-corruption compliance risks and program development.

As a member of Covington’s Business and Human Rights practice group, Sarah advises companies on the developing legal and enforcement landscape related to the corporate responsibility to respect human rights. She advises on enforcement risks under Withhold Release Orders (WROs), the Uyghur Forced Labor Prevention Act (UFLPA), and the Trafficking Victims Protection Reauthorization Act (TVPRA) in the United States, as well as developing EU human rights laws. Sarah has helped multinational corporations in the healthcare, technology, automotive, energy, mining, and consumer goods sectors develop human rights due diligence programs, navigate human rights-related enforcement matters, and report on human rights due diligence efforts.

Sarah has extensive experience conducting internal and government-facing white collar investigations. Sarah has conducted investigations involving allegations of bribery, money laundering, export control and sanctions violations, fraud, human rights violations, and other forms of misconduct. She has handled matters before major international enforcement authorities and has been recognized in the Global Investigations Review Women in Investigations survey.

Sarah also assists clients in suspension and debarment matters before the World Bank and other international financial institutions.