Sanctions regime—global anti-corruption
Produced in partnership with John Binns of BCL Solicitors LLP

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

  • Sanctions regime—global anti-corruption
  • Global Anti-Corruption Sanctions Regulations 2021
  • Bribery
  • Misappropriation of property
  • Involvement in serious corruption
  • Who can be subject to sanctions?
  • Prohibitions and requirements
  • Application
  • Financial sanctions
  • Immigration
  • More...

Sanctions regime—global anti-corruption

Financial sanctions target behaviour and have traditionally been aimed at:

  1. terrorism

  2. nuclear weapons development

  3. human rights abuses—see Practice Note: Sanctions regime—global human rights

However, financial sanctions are increasingly creeping into the realms of more general criminal law, with sanctions previously imposed in relation to the misappropriation of state funds and cyberattacks. The UK has now introduced a global anti-corruption sanctions regime, aimed at preventing and combatting serious corruption. The global anti-corruption sanctions regime came into force on 26 April 2021.

This Practice Note explains the scope of the UK global anti-corruption sanctions regime. It explains the activities targeted by the regime, the sanctions imposed, who is covered and the relevant guidance published by the Office of Financial Sanctions Implementation (OFSI). It also considers practical aspects of the regime for businesses.

For information on the statutory aims for the creation of sanctions regimes under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018), the obligations to publish guidance on those regimes and how designations may be made, varied and enforced, see Practice Note: The UK sanctions framework under SAMLA 2018.

Global Anti-Corruption Sanctions Regulations 2021

The Global Anti-Corruption Sanctions Regulations 2021, SI 2021/488 enable financial sanctions and travel bans to be imposed on persons involved in serious corruption. They replace the Misappropriation (Sanctions) (EU Exit) Regulations 2020, SI 2020/1468 concerning misappropriation of state funds from any country outside the

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