Development of sanctions regime in the UK post Brexit—timeline
Development of sanctions regime in the UK post Brexit—timeline

The following Corporate Crime guidance note provides comprehensive and up to date legal information covering:

  • Development of sanctions regime in the UK post Brexit—timeline
  • Scope of this timeline
  • How do sanctions affect businesses?
  • Who is responsible for the development of sanctions policy?
  • What impact does Brexit have on the UK sanctions regime?
  • Passing of SAMLA 2018
  • Key provisions of SAMLA 2018
  • Developments since the passing of SAMLA 2018
  • Timeline of key events in development of UK Sanctions regime
  • The Sanctions and Anti-money Laundering Bill in further detail

Scope of this timeline

There are different sanctions regimes which affect UK businesses. Usually they are grouped into trade and financial sanctions:

  1. trade sanctions (also known as embargoes) restrict trade and business with certain countries and impose either a prohibition or a licensing requirement on the sale, supply, transfer, export or import of specified items to or from a specified country and include economic travel bans, or financial or diplomatic restrictions, and

  2. financial sanctions are measures which restrict dealings in money and the provision of financial services and include the prohibition of funds transfers to certain countries, individuals or entities

For further information, see Practice Notes:

  1. International sanctions—an introduction

  2. Trade sanctions—an introduction

  3. Financial sanctions—offences

Lawyers and companies they advise need to understand what their sanctions risk is in order to develop and implement an appropriate compliance strategy. Yet the landscape of sanctions compliance is changing as a result of the UK’s decision to leave the EU.

The legal terms of the UK’s withdrawal from the EU are set out in the Withdrawal Agreement, which is an international treaty implemented in domestic law by the European Union (Withdrawal Agreement) Act 2020 (EU(WA)A 2020). As of exit day, the UK is no longer an EU Member State, but it has entered an implementation period during which it continues to be treated by the EU