Understanding the sanctions regime—a guide for businesses
Understanding the sanctions regime—a guide for businesses

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

  • Understanding the sanctions regime—a guide for businesses
  • What are sanctions and who imposes them?
  • Administration and enforcement
  • Offences and penalties
  • Key elements of the sanctions regimes
  • The financial sanctions regime v the AML regime

UNDER REVIEW: The Sanctions and Anti-money Laundering Act 2018 received Royal Assent on 23 May 2018. It introduces a new framework for the implementation and enforcement of international sanctions in the UK with the purpose of enabling the UK's continued compliance with international law post-Brexit. The Act enables an appropriate minister to make regulations imposing sanctions and to use sanctions to meet foreign policy and national security objectives after exiting the EU. It provides for the implementation of civil and criminal enforcement for sanctions regimes through secondary legislation. Practice Note: Development of sanctions regime in the UK post Brexit—timeline tracks the development of The Sanctions and Anti-money Laundering Act 2018. Several provisions of the Act dealing with reporting, commencement and interpretation are already in force. This Practice Note will be updated as and when further implementing legislation is published.

This Practice Note explains what trade and financial sanctions are and who imposes them, how sanctions are administered and enforced, brief details of related offences and penalties, key concepts and how the financial sanctions regime is different from the anti-money laundering (AML) regime.

For more on offences, penalties, investigations and enforcement, see Practice Note: Trade and financial sanctions offences, penalties, investigations and enforcement—a guide for businesses.

What are sanctions and who imposes them?

Sanctions are non-permanent international restrictions or prohibitions aimed at:

  1. encouraging a change in the behaviour of