UK & Europe
This is the first post in a series which considers the future of the United Kingdom's sanctions policy following its withdrawal from the European Union.
Written by Patrick Murphy and Qi Jiang
HM Treasury's Office for Financial Sanctions Implementation (OFSI) has recently issued guidance updated guidance on financial sanctions following the withdrawal of the United Kingdom from the European Union on 31 January 2020.
The key points that you will need to be aware of are:
Whilst UK and EU officials have repeatedly stated that they intend to coordinate as much as possible on sanctions policy, there are already signs of potential divergence which may require companies doing business in the UK to adjust their sanctions compliance practices.
For example, the UK government has already given signs that it is willing to enact its own autonomous sanctions. The UK Foreign Office has signalled it will utilise the new SAMLA powers post-Brexit to introduce 'Magnitsky-style' designations of those suspected of human rights violations and corruption. SAMLA will allow UK to act more quickly than the EU to introduce such designations, which requires bloc-wide consensus for such designations to be made.
In our next post, we will consider some areas of potential divergence between the EU and UK going forward.