Financial Sanctions

Abstract This chapter analyses the UK’s financial sanctions framework under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), focusing on the Russia (Sanctions) (EU Exit) Regulations 2019. It traces the evolution from asset freezes to broader measures such as correspondent banking restrictions, investment and loan bans, and prohibitions on dealing in securities and money market instruments. Key terms—‘funds’, ‘economic resources’, and ‘designated persons’—are defined, with the ownership and control test examined in light of OFSI guidance and case law including Mints and Litasco SA. Jurisdictional scope, exceptions for prior obligations and humanitarian aid, and anti-circumvention rules are also considered. The chapter details licensing grounds, general and specific licences, appeal mechanisms, and reporting duties for firms and designated persons. Enforcement routes—civil penalties, prosecutions, deferred prosecution agreements, and serious crime prevention orders—are reviewed, noting the inclusion of strict civil liability since 2022. It concludes with compliance challenges and the balance between diligence and sanctions severity.