Regulatory & International Trade | RIT
Helping businesses clear legal regulatory hurdles in Europe
Regulatory & International Trade | RIT
Regulatory & International Trade | RIT
Helping businesses clear legal regulatory hurdles in Europe

Sabine Naugès

Sabine Naugès counsels clients on all aspects of public law, including administrative and regulatory, competition and constitutional law. Among other high-profile clients, Sabine has advised telecommunications companies France Télécom and Orange on regulatory matters in cases before administrative and commercial courts, and before EU and French competition authorities. She also regularly represents major companies with interests in a wide range of industries, including aerospace, energy, oil and gas, and public health care, before the French government and in litigation, in a range of regulatory and administrative matters.

FSR Guidelines 2026 | “Safe harbours” for call ins: Comfort, not a free pass


By , , and on Jan 14, 2026
Posted In Foreign Subsidies

The final FSR Guidelines, adopted on January 9, 2026, do not expand the Commission’s legal powers under the Foreign Subsidies Regulation (Regulation (EU) 2022/2560). What they do offer is a more calibrated, and more operational, statement of enforcement intent, particularly around when the Commission may require prior notification of otherwise non notifiable deals or tenders....

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French FDI review 2025: Practical lessons and regulatory outlook


By and on Jan 7, 2026
Posted In France, Foreign Investment

2025 enforcement trends The French Foreign Direct Investment (FDI) Bureau confirmed in 2025 the trends observed in 2024, notably a continued increase in the number of notifications, including a significant volume of filings linked to collective insolvency proceedings. The Bureau emphasized that its review process is grounded in objective, non-discriminatory, transparent, and predictable criteria. Ongoing dialogue between investors...

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Securing Strategic Sectors: Insights from McDermott’s Defense & Essential Infrastructure Roundtable


By , , , , and on Nov 14, 2025
Posted In France

In October 2025, McDermott Will & Schulte hosted its Defense & Essential Infrastructure Roundtable, convening leading voices from across government, industry, and finance to discuss the challenges facing Europe’s most sensitive sectors. The session featured insights from McDermott partners Sabine Naugès, Bertrand Delafaye, Charlotte Michellet, Guillaume Kellner, Romain Desmonts and Romain Perray, who examined how organisations can...

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Quarterly Sanctions Update | Q3 2025


By , and on Sep 19, 2025
Posted In France, Sanctions & Export Control, United Kingdom

The third quarter of 2025 marks greater coordination between the European Union and United Kingdom on sanctions, specifically with respect to lowering the price cap on Russian oil, broadening the range of targeted individuals and entities, and introducing new measures against sanctions circumvention via third countries. Key developments also include new sectoral restrictions, expanded export...

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Quarterly Sanctions Update | Q2 2025


By , , and on May 12, 2025
Posted In Sanctions & Export Control

What’s New? In the second quarter of 2025, EU and UK sanctions policy continued to take shape against a complex and shifting geopolitical backdrop. The European Union sharpened its focus on Russia’s ‘shadow fleet’ by proposing new sanctions, while also launching a Helpdesk to support small and medium-sized enterprises in navigating compliance requirements. Meanwhile, the...

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Quarterly Sanctions Update | Q4 2024 / Q1 2025


By , , and on Feb 28, 2025
Posted In United Kingdom

What’s New? The European Union and the United Kingdom remain committed “to keep up the pressure on the Kremlin” by way of imposing further sanctions as Russia’s illegal invasion of Ukraine enters the fourth year. Within a course of the last three months, the EU adopted two new sanctions packages, with new restrictions ranging from asset...

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Navigating EU Sanctions: How Investment Funds and Corporates Can Meet the ‘Best Efforts’ Standard


By , , , and on Nov 29, 2024
Posted In Foreign Investment, Sanctions & Export Control

With the introduction of the 14th sanctions package, entities established in the European Union are required to ‘undertake their best efforts to ensure’ that non-EU subsidiaries they own or control do not undermine EU Regulation 833/2014 imposing EU sanctions against Russia, or EU Regulation 765/2006 imposing EU sanctions against Belarus. This obligation stretches to EU...

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New US Sanctions Against Gazprombank and Several Russian Financial Institutions


By , and on Nov 25, 2024
Posted In Sanctions & Export Control, Energy

The US Treasury’s Office of Foreign Assets Control (OFAC) has implemented sanctions on additional Russian financial institutions, notably Russia’s Gazprombank and several foreign subsidiaries. These blocking sanctions prohibit US persons and entities from transacting with Gazprombank or its listed subsidiaries, as well as any entity owned 50% or more by Gazprombank or any other sanctioned...

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Understanding French Export and Re-Export Prohibitions: Ministry of Armed Forces Releases FAQ on Non Re-Exportation Certificates


By and on Nov 22, 2024
Posted In France, Sanctions & Export Control

On October 10, 2024, the French Ministry of Armed Forces released an FAQ relating to a Non-Re-Exportation Certificate (NRC), available in French here (FAQ). This document provides practical guidance to military companies exporting equipment covered by the prohibition on export or re-export to sanctioned countries. The FAQ complements the existing guidelines for completing certificates required...

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Quarterly Sanctions Update | Q3 2024


By , and on Oct 8, 2024
Posted In Sanctions & Export Control

Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week, however, a new package of sanctions aimed at tackling hybrid operations by the Russian government has been agreed upon, and is expected...

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