Designation of sanctions targets under the UN sanctions, EU sanctions and UK terrorist asset-freezing regimes
Produced in partnership with Roger Matthews of Dentons
Designation of sanctions targets under the UN sanctions, EU sanctions and UK terrorist asset-freezing regimes

The following Corporate Crime guidance note Produced in partnership with Roger Matthews of Dentons provides comprehensive and up to date legal information covering:

  • Designation of sanctions targets under the UN sanctions, EU sanctions and UK terrorist asset-freezing regimes
  • Impact of sanctions designations
  • UN sanctions listing
  • EU-level Designations
  • UK Designations under the Terrorist Asset-Freezing etc Act 2010

This Practice Note explains the process of the designation of sanctions targets by the UN, EU and in the UK under the Terrorist Asset-Freezing etc Act 2010 (TAFA 2010). This is the current regime for the designation of sanctions in the UK as EU sanctions continue to apply in the UK during the implementation period.

Practitioners should note that in its preparations for the end of the implementation period, the UK has passed the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) which creates a power for ministers to pass sanctions regulations and creates a mechanism for the designation of sanctions and to challenge designations. See Practice Note: Development of sanctions regime in the UK post Brexit—timeline. A number of statutory instruments creating UK sanctions have been passed in readiness for the end of the implementation period (see Practice Note: Brexit legislation tracker for corporate crime practitioners) and some elements of these regulations, including the power to designate, have been commenced. However, as yet there are no consequences to being designated under SAMLA 2018 regime because the provisions imposing the consequences have not yet been commenced. Currently therefore, the UK does not yet have any power under SAMLA 2018, or the regulations made under it to impose an asset-freeze. It is anticipated that these powers will come into force at the