The Post-Brexit UK Sanctions Framework

Abstract This chapter provides an overview of the UK’s sanctions framework following its EU exit, established under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). It details ministerial powers to enact regulations for UN compliance, terrorism prevention, national security, and foreign policy objectives, with amendments by the Economic Crime (Transparency and Enforcement) Act 2022 (ECTEA) lowering designation thresholds by removing the ‘appropriateness’ criterion. Key government bodies—Foreign, Commonwealth and Development Office (FCDO), Office of Financial Sanctions Implementation (OFSI), Office of Trade Sanctions Implementation (OTSI), and others—are outlined, alongside sanction types: financial, trade, immigration, aircraft, and shipping. It examines SAMLA’s impact on the Policing and Crime Act 2017 (PCA), uniformly increasing criminal sentences to 10 years, civil penalty frameworks, enforcement powers, review rights against OFSI/OTSI decisions, officer liability, and licensing regimes (general and specific), including legal fees provisions under the Russia Regulations.