Financial sanctions—offences
Produced in partnership with Dentons
Financial sanctions—offences

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

  • Financial sanctions—offences
  • Financial sanctions and legislative regime during the implementation period
  • Offences
  • Scope of financial sanctions offences
  • Definitions
  • Exclusions and defences
  • Penalties for breach of financial sanctions
  • Financial sanctions offences after implementation period completion day

Financial sanctions and legislative regime during the implementation period

As of exit day (31 January 2020), the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an implementation period, during which it continues to be subject to EU law. This has an impact on this Practice Note. For further guidance, see Practice Notes: Brexit—introduction to the Withdrawal Agreement and Development of sanctions regime in the UK post Brexit—timeline as well as Brexit Bulletin—key updates, research tips and resources.

Financial sanctions prohibitions are set out in EU Regulations and relevant UK Statutory Instruments (SIs) relating to the country-specific sanctions regime. There is a relevant SI for each of the sanctions regimes in place (for example, see the Libya (European Union Financial Sanctions) Regulations 2016, SI 2016/45). In accordance with the terms of the Withdrawal Agreement, during the implementation period, the EU regulations remain directly applicable in the UK. The UK SIs set out in more precise detail what constitutes an offence, but the EU Regulations and UK SIs should be read together. If there is any apparent difference between the two, the UK SI should be interpreted in a way that is consistent with the underlying EU Regulation, even if this is not its most natural interpretation. If the two are