UK sanctions regimes currently in force

The following Risk & Compliance practice note provides comprehensive and up to date legal information covering:

  • UK sanctions regimes currently in force
  • UK/EU sanctions divergence
  • Geographic
  • Thematic

UK sanctions regimes currently in force

This Practice Note provides information on UK sanctions regimes currently in force, including regimes under the Sanctions and Anti-Money Laundering Act 2018, the Anti-Terrorism, Crime and Security Act 2001 (ACSA 2001) and the Export Control Order 2008, SI 2008/3231. It also identifies the equivalent EU sanctions regime, where applicable, and provides useful further reading resources for each UK regime.

A regime is a collection of sanctions measures put in place for a particular set of purposes. Regimes can be either:

  1. geographic—relating to a particular country or region, or

  2. thematic—relating to a particular issue

For further information on sanctions, see subtopics: Financial sanctions, trade sanctions and export controls, Sanctions & export controls compliance and for law firms: Financial sanctions—law firm compliance.

UK/EU sanctions divergence

In practice, while the UK government has stated that the SAMLA 2018 regulations are intended to deliver substantially the same policy effect as the equivalent EU regimes, there are differences (with varying impacts) between some of the UK/EU regimes.

For example, one such difference has been the introduction of the new concept of ‘persons connected with’ a sanctioned country in a number of the UK statutory instruments made under SAMLA 2018 which expands the application of the UK regime beyond that in the EU equivalent.

Another example is the difference in certain defined terms (‘financial services’ in UK regimes, as

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