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Sanctions are how governments apply pressure without resorting to force, by restricting the money, trade and movement of the countries, companies and individuals they want to constrain. For a business, a single designation can freeze accounts, void contracts and expose the company to fines or criminal liability for a breach it never intended. For a victim of corruption or abuse, a well-placed sanction can reach a person no court has been able to touch. IHR Advisors, founded by lawyers Ben Keith and Rhys Davies, works on both sides of that line: helping clients stay within the rules or remove themselves from a list, and helping NGOs and victims put the right people on one.
Sanctions do not come from a single source, and a person or company can be caught by several regimes at once.
The UK regime operates under the Sanctions and Anti-Money Laundering Act 2018, covering financial, trade and immigration measures. The US regime is the widest-reaching of all, built on laws such as the International Emergency Economic Powers Act and administered by the Office of Foreign Assets Control, known as OFAC, whose rules bind far beyond US borders. The EU runs its own measures through Council regulations. At the international level, the UN Security Council maintains a series of sanctions regimes that member states are required to implement, and the multilateral development banks, including the World Bank, can debar firms and individuals from the projects they finance for fraud or corruption.
Magnitsky sanctions sit across several of these systems. Named after Sergei Magnitsky, the auditor who uncovered a large state fraud in Russia and died in prison after exposing it, they target named individuals for human rights violations and corruption rather than sanctioning an entire state. The firm advises on how these designations are obtained, what a listing means for the person named, and the consequences for companies and counterparties doing business with anyone caught by one.
The development banks run a sanctions system of their own, and it catches companies and individuals who never expected to be caught by one. The World Bank, the Inter-American Development Bank, the African Development Bank, the Asian Development Bank and the European Bank for Reconstruction and Development each investigate and debar firms and people involved in fraud, corruption, collusion, coercion or obstruction on the projects they finance. A debarment can bar a company from bank-financed work for years, and it rarely stays with the bank that imposed it. Under a mutual enforcement agreement signed in 2010, a debarment of more than a year by one bank is enforced automatically by the others, so a single finding can close off projects across the whole system. More than five hundred entities had been cross-debarred this way by 2017, and the number has kept climbing.
What makes these proceedings dangerous is that they carry criminal-scale consequences without criminal safeguards. A sanction is decided on the balance of probabilities, not proof beyond reasonable doubt, and the banks define corruption far more widely than most national criminal codes: no public official need be involved, no minimum value applies, and no specific quid pro quo need be shown. No court tests the finding before it takes effect. The result is still public, listed by name, disclosable in every future tender, and increasingly shared with national prosecutors, so a debarment often arrives before, not after, a criminal investigation. Rhys Davies and Cristian González Ruiz set this out in their International Bar Association article, Parallel Tracks, drawing on the Inter-American Development Bank’s system in Latin America.
We act for companies, contractors, consultants and individuals under investigation by a bank’s integrity office: responding to the investigation, answering the sanctions case, negotiating settlements and compliance conditions, and appealing to the sanctions board. Because a bank proceeding and a criminal inquiry now move together, we handle the exposure on both fronts at once.
Sanctions law rewards people who know the regimes from the inside. The same activity can be lawful under one system and prohibited under another, a licence that solves the problem in one jurisdiction may not exist in the next, and the consequences of getting it wrong run from financial penalty to criminal liability. Advice that treats sanctions as a single set of rules misreads the field.
The two sides of the practice are an advantage here. A firm that argues for designations on behalf of victims understands how listing decisions are actually made, and a firm that challenges wrongful listings knows where those decisions are weak. Each side sharpens the other, and a client gets the benefit of both.
Ben Keith acts across international human rights, sanctions and cross-border enforcement, advising clients caught by sanctions regimes and acting for those pursuing accountability against states and individuals that operate beyond the reach of any national court. He is a lawyer at 5SAH in London, ranked for extradition and international work in both Chambers and Partners and the Legal 500, the former describing him as “out of this world”.
In 2021 he co-wrote Undue Influence: The UAE and INTERPOL with Rhys Davies and Sir David Calvert-Smith, setting out how political interference reached an international institution’s own leadership, and the report fed directly into the case for reform. He has appeared on CBS 60 Minutes, written for the Financial Times, given evidence to the UK Parliament’s Joint Committee on Human Rights, and co-founded Red Notice Monitor, where he edits and publishes legal analysis of INTERPOL cases and policy.
Rhys Davies has built the same kind of practice from a different chair: cases spanning sanctions, torture, extradition and politically motivated prosecution across several jurisdictions, and communications to the United Nations where a case calls for them. He is a lawyer at Temple Garden Chambers in London and The Hague, ranked as a leading individual by the Legal 500 2026, which calls him “a standout international lawyer” and the lawyer others turn to for UN submissions in difficult cases.
He has written on international law for The Economist, Newsweek, City A.M., the Guardian, The Times and the Independent, appears regularly on Al Jazeera, and has featured on CBS 60 Minutes and the Sky News Dirty Work podcast. He co-founded and edits Red Notice Monitor, and in 2025 he gave evidence, alongside Ben Keith, to the Joint Committee on Human Rights.
Ben Keith and Rhys Davies founded IHR Advisors to keep the legal work, the strategy and the press handling of these matters in one place, because in practice they cannot be pulled apart. Sanctions work is rarely a single piece of advice, and the firm runs the whole of it: assessing exposure across the regimes that apply, preparing licence applications, challenging wrongful designations and pursuing them where a victim needs one, handling the publicity that often surrounds a sanctions matter, and working with local and specialist counsel in each jurisdiction involved.
In one matter the firm advised a large international non-governmental organisation on whether, and how, sanctions could be obtained under a Council of Europe regime relating to Lebanon. The people and bodies it acts for are companies and their officers, NGOs and civil society organisations, politically exposed persons, high net worth individuals and the victims of corruption and abuse who are seeking redress.
It is the work of keeping a company, organisation or individual within the rules of the sanctions regimes that apply to them. It covers assessing what activity is permitted, obtaining the licences needed for restricted dealings, and avoiding the penalties, financial and sometimes criminal, that follow a breach.
There is a defined legal route to challenge a designation and seek removal from the list. A delisting case sets out why the listing is wrong or no longer justified and puts that case to the authority responsible for the regime.
They are targeted measures against named individuals responsible for serious human rights abuses or corruption, rather than sanctions against a whole country. They are named after Sergei Magnitsky, who died in a Russian prison after uncovering a major state fraud. The firm advises on how a designation is obtained, what it means for the individual named, and the exposure it creates for businesses dealing with them.
A person or business can be caught by several at once, most commonly the UK, US, EU and UN regimes, and sometimes the multilateral development banks such as the World Bank. The same activity can be lawful under one and prohibited under another, which is why advice across the regimes together matters.
Yes. The World Bank and the other multilateral development banks can debar companies and individuals from the projects they finance for fraud, corruption or related misconduct, on a lower standard of proof than a criminal court, and a debarment by one bank is usually enforced by the others. We act for those under investigation by a bank’s integrity office and in the sanctions proceedings that follow.
Contact IHR Advisors through the contact page on this site. Ben and Rhys take instructions from companies, organisations, individuals and the legal teams advising them, and early advice keeps options open before a problem becomes a breach.
Whether you need to operate safely within a sanctions regime, challenge a listing that should not stand, or seek sanctions against those who have harmed you, take advice early. The regimes overlap, they change quickly, and the cost of acting on the wrong assumption is high. A sanctions lawyer can usually tell you, inside a single conversation, where you stand and what can be done about it.
If you would like to speak with us about our areas of practice or anything else please contact us via the form linked below.
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