The UK sanctions framework under SAMLA 2018
Produced in partnership with John Binns of BCL Solicitors LLP
The UK sanctions framework under SAMLA 2018

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:

  • The UK sanctions framework under SAMLA 2018
  • What is the background to the UK’s domestic sanctions regime?
  • The sanction framework pre-Brexit and during the implementation period
  • The domestic sanctions regime—primary legislation
  • The roles of the FCDO and OFSI
  • A purposive approach to domestic sanctions
  • International obligations and ‘discretionary purposes’
  • Gross violation of human rights sanctions ('Magnitsky sanctions')
  • Regulations for a ‘discretionary purpose’—additional requirements
  • Types of sanctions under the UK’s sanctions regime
  • More...

The UK sanctions framework under SAMLA 2018

This Practice Note explains the UK financial sanctions and trade 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 UN sanctions obligations. Those UK sanctions made under SAMLA 2018 which replaced existing EU or UN sanctions came 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.

What is the background to the UK’s domestic sanctions regime?

‘Sanctions’ is the term used for a range of measures designed to have an adverse impact on foreign countries or designated persons (individuals or corporate bodies), for one or more specified (often foreign policy, sometimes counter-terrorism) purposes. The measures apply prohibitions and requirements on the targets directly, but also on third parties who trade or otherwise deal with them. For detailed guidance, see Practice Note: International sanctions—an introduction—What are sanctions?

The sanction framework pre-Brexit and during the implementation period

Historically, most of the UK’s sanctions regimes came from the European Union (EU), in the form of EU Regulations that have

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