Imogen Brooks, Associate, International Trade

Imogen Brooks

Counsel

Areas of Focus

Imogen Brooks, Associate, International Trade

Imogen Brooks

Counsel

imogen.brooks@akingump.com

Areas of Focus

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Biography
  • Areas of experience include economic and trade sanctions, export controls, customs and import compliance, national security reviews, and anticorruption and anti-money laundering (AML) compliance.

Imogen Brooks is a recommended lawyer in The Legal 500 UK for Trade, WTO Anti-Dumping, Customs and Sanctions (2026, 2022). She brings extensive experience advising multinational clients on complex international trade compliance matters, including economic and trade sanctions, export controls, customs, national security reviews, and anti-bribery and corruption (ABC) and anti-money laundering (AML) matters.

Imogen’s experience spans risk assessments for cross-border transactions, obtaining critical regulatory licenses and authorisations for clients, development of compliance programs, internal investigations, voluntary disclosures, and negotiations with regulators. She has advised clients across sectors such as energy, semiconductors, quantum computing, high-tech, telecommunications, aerospace and defence, commodity trading, investment funds, private equity, and pharmaceuticals.

Representative Work
  • Advising a global telecoms company on a US$5.5 billion divestment from Russia, securing essential licenses and regulatory clearances under UK, EU, and Bermuda sanctions regimes.
  • Leading complex sanctions and trade compliance workstreams for a multinational group, including acquisition of securities trapped in Russian infrastructure and negotiation of key transaction protections.
  • Obtaining critical sanctions licenses for multiple high-value restructurings and commercial transactions, ensuring compliance and continuity for global businesses under restrictive regimes.
  • Providing strategic sanctions and export control advice to a leading aerospace and technology company on operations in high-risk jurisdictions, ensuring lawful and commercially viable market access.
  • Supporting major energy companies on implementation of the G7 Price Cap Policy, drafting compliance clauses and advising on multi-jurisdictional trading operations across Europe, the Middle East, and Asia.
  • Delivering sanctions analysis for an international shipping group, clarifying asset freeze implications and mitigating regulatory risk under EU and UK frameworks.
  • Leading UK export control classification projects for advanced technology manufacturers, developing robust compliance frameworks for dual-use and military-grade components.
  • Managing a UK export control voluntary self-disclosure and regulatory engagement for a quantum computing company, achieving closure of an export control breach investigation without penalties.
  • Conducting multijurisdictional trade compliance, ABC, and AML investigations for global corporates.
  • Advising on sanctions and international trade control risks in connection with M&A transactions and other trade-related provisions in related financings.
  • Advising on customs and import compliance for multinational pharmaceutical and technology clients, addressing trade barriers, rules of origin, and incoterms.
  • Advising global financial institutions on sanctions screening and data protection compliance, balancing regulatory obligations with privacy requirements in cross-border transactions.
  • Supporting UK government negotiations on free trade agreements, providing technical input on trade compliance and regulatory alignment.

Education
  • L.P.C., BPP University Law School, England, 2017

  • LL.B., London School of Economics and Political Science, 2015

Bar Admissions
  • Solicitor, England and Wales

Recognitions
  • The Legal 500 UK, Recommended Lawyer in Trade, WTO Anti-Dumping, Customs and Sanctions - 2026, 2022.

Insights and Achievements

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              Distinguished by our areas of focus, as a cohesive and integrated firm, we are defined by the caliber of our work, the responsiveness of our service and a culture that is rooted in collaboration and forward-thinking.

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