Challenging UK sanctions designations under SAMLA 2018
Produced in partnership with John Binns of BCL Solicitors LLP

The following Corporate Crime practice note produced in partnership with John Binns of BCL Solicitors LLP provides comprehensive and up to date legal information covering:

  • Challenging UK sanctions designations under SAMLA 2018
  • The impact of a sanctions designation
  • Sanctions designations under SAMLA 2018
  • The basis of SAMLA 2018 sanctions designations
  • UN-named persons
  • Required conditions for a designation
  • Designation by description
  • How to approach challenging sanctions designations
  • The legality of UK sanctions regulations
  • Specification of activity
  • More...

Challenging UK sanctions designations under SAMLA 2018

This Practice Note explains the UK domestic sanctions regime under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). This regime was implemented to ensure the UK has a robust sanctions regime after the UK leaves the EU (Brexit) and enables the UK to impose financial sanctions, immigration sanctions, trade sanctions, aircraft sanctions, shipping sanctions and other sanctions needed to comply with United Nations (UN) sanctions obligations. Those UK sanctions made under SAMLA 2018 which replaced EU or UN sanctions were brought into force fully at the end of the implementation period (IP completion day). For further guidance, see Practice Note: Development of sanctions regime in the UK post Brexit—timeline.

SAMLA 2018 also contains provisions that allow the UK to create a sanctions regime for purposes that would provide accountability for or be a deterrent to ‘gross violations of human rights’ (conduct that is, broadly speaking, connected with political torture), or otherwise promote compliance with human rights law or respect for human rights, popularly referred to as ‘Magnitsky sanctions’. The UK’s human rights sanctions regime was implemented by the Global Human Rights Sanctions Regulations 2020, SI 2020/680. This regime came into force on 6 July 2020.

For information on the UK domestic sanctions regime under SAMLA 2018, see Practice Notes: The UK sanctions framework under SAMLA 2018 and UK sanctions

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