Following the end of the Brexit transition period on 31 December 2020, the UK is no longer subject to the EU sanctions framework. The Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act) is now the governing legislation for sanctions in the UK, supported by additional regulations implementing specific sanctions programmes.
The new sanctions laws give effect to the UK’s obligations under United Nations sanctions programmes. They are also broadly equivalent, in principle, to the EU regime, though not entirely identical and there are some important differences within the details of each programme. The Office of Financial Sanctions Implementation (OFSI) will continue to maintain the UK’s Consolidated List of financial sanctions targets. The Foreign & Commonwealth Office has published high level guidance on the UK’s new sanctions framework as well as an overview of current sanctions regimes.
