Overview of UK Sanctions

December 4, 2025
Posted by: Amaya Emmanuel
Category: General

Sanctions are a key component of the UK’s foreign policy and national security strategy. They are used to influence the behaviour of states, individuals, and entities that threaten international peace and security, violate human rights, or undermine democratic institutions. Following the UK’s exit from the EU, the UK adopted and now operates a fully independent sanctions framework through the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). SAMLA is the primary legislation empowering UK Ministers to create sanctions regimes for national security, international peace and security, human rights, and foreign policy objectives. This framework enables the UK government to impose, amend and enforce sanctions autonomously, while still coordinating closely with allies such as the US, the EU and the UN.

Sanctions and Anti-Money Laundering Act 2018 (SAMLA)

The foundation of the UK sanctions regime is the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). SAMLA grants powers to the UK Government, particularly the Secretary of State for Foreign, Commonwealth and Development Affairs (FCDO) and the HM Treasury, to make regulations imposing: trade sanctions, financial sanctions, immigration restrictions and transport and shipping controls.

The Act is implemented through a series of statutory instruments (sanctions regulations), each tailored to a specific country regime or thematic purpose. Some examples are: Russia and Belarus (Sanctions) (EU Exit) Regulations 2019, Global Human Rights Sanctions Regulations 2020, Global Anti-Corruption Sanctions Regulations 2021 and the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019. Some examples of complementary legislation include: Export Control Order 2008 (trade and dual-use goods), Money laundering regulations 2017 (due diligence and reporting duties), and Proceeds of Crime Act 2002 (POCA) for enforcement of asset freezes.

Types of Sanctions

UK sanctions can be country-specific or thematic, and they generally fall into five categories: financial sanctions, trade sanctions, immigration sanctions, transport and shipping sanctions and thematic regimes.

Financial Sanctions prohibit dealing with the funds or economic resources of designated persons or entities and prevent making funds or resources available to them. This includes: asset freezes, restrictions on financial services and investment or capital-market bans. Financial sanctions apply to UK persons worldwide, including banks, insurers and professional service providers. The Office of Financial Sanctions Implementation (OFSI) within HM Treasury administers and enforces these measures.

In terms of trade sanctions, these regulate the export, import, supply or delivery of goods and technology, including: arms embargoes, export controls on dual-use items, restrictions on oil, gold or other commodities and bans on the provision of technical assistance or brokering services. Trade sanctions are enforced by HM Revenue and Customs (HMRC) and the Department for Business and Trade (DBT).

Immigration measures prevent designated individuals from entering or remaining in the UK. They are implemented by the Home Office, often in conjunction with other sanctions, such as travel bans imposed on human rights violators.

Transport and Shipping Sanctions restrict access to UK airspace and ports by sanctioned aircraft or vessels. Under the Shipping (Sanctions) (EU EXit) Regulations 2019, the UK can detain or refuse entry to vessels owned, controlled, or operated by designated persons and prohibit UK nationals or entities from chartering, insuring or maintaining such vessels.

In terms of thematic regimes, beyond state-based sanctions, the UK applies thematic regimes addressing global misconduct, including: human rights abuses (Global Human Rights Sanctions Regulations 2020), corruption (Global Anti-Corruption Regulations 2021) and cyber operations, chemical weapons and terrorism financing.

Application of UK Sanctions

All sanctions apply to individuals located in the UK and UK nationals and legal persons (companies, partnerships, etc) worldwide. This therefore includes UK citizens and companies’ overseas branches.

Those named on the UK Sanctions List maintained by the FCDO are subject to restrictions. The list specifies the legal basis for designation, the type of sanction and any applicable exemptions (eg for basic living expenses or legal fees).

Sanctions also apply indirectly to third parties who act “for or on behalf of” designated persons. For instance, providing funds, goods or services to a sanctioned entity’s subsidiary may constitute a breach.

Designated persons may request a review of their designation under SAMLA or challenge it in court via judicial review before the High Court (or Court of Session in Scotland). The independent reviewer of sanctions regulations, appointed by Parliament, reviews the proportionality and fairness of the UK sanctions regime annually.

Licence Applications and Enforcement Bodies

Sanctions can be imposed by statutory instrument under SAMLA when required to comply with UN Security Council resolutions, to further UK foreign policy or national security or to promote compliance with international human rights or humanitarian law. Each regulation specified the scope and duration of the sanctions, the designation criteria and available licensing grounds (eg for humanitarian relief, diplomatic purposes, or legal services).

Certain activities that would otherwise breach sanctions can be authorised through OFSI licences (for financial transactions) or DBT export licences (for controlled goods). Applicants must demonstrate that the proposed activity falls within a permitted purpose (eg medical supplies, family remittances, or UN-approved operations).

The Enforcement Bodies are OFSI (HM Treasury), which investigates and enforces financial sanctions, HMRC, which enforces trade and export controls, National Crime Agency (NCA), which investigates criminal breaches and Crown Prosecution Service (CPS), which prosecutes offences under sanctions legislation.

Sanctions Breaches

Violations of sanctions legislation are serious criminal offences, and the penalties include: civil monetary penalties up to the greater amount of £1 million or 50% of the value of the breach (OFSI administrative powers). Another penalty is criminal penalties, meaning imprisonment of up to 7 years (under SAMLA 2018, s.146), unlimited fines and forfeiture of assets involved in the breach. OFSI encourages voluntary disclosure of breaches. Cooperation can mitigate penalties, especially where an organisation demonstrates robust compliance systems.

Compliance with UK Sanctions

All UK firms, predominantly those in finance, legal, logistics and technology sectors, must screen clients, suppliers and counterparties against the UK Sanctions List, maintain internal compliance policies and escalation procedures, train staff on red flags (eg suspicious intermediaries, ownership opacity) and keep detailed records of screening and due diligence for at least 6 years.

UK entities must also verify the ultimate beneficial owner (UBO) of any counterparty to ensure no indirect dealings with sanctioned persons. Where a transaction involves multiple jurisdictions (eg UK, EU, US), firms must comply with all applicable sanctions regimes. In practice, the most restrictive regime governs.

Emerging Trends

Some findings on current and emerging trends include: Russia and Belarus sanctions, which remain the most extensive, including price caps on oil and restrictions on luxury goods and services and integration of sanctions screening with anti-money-laundering (AML) compliance.

The UK’s sanctions regime is now a fully autonomous, sophisticated system combining legislative authority, targeted measures and coordinated international enforcement. Compliance is not optional and all UK persons and businesses, whether that be financial institutions, exporters or digital platforms, must ensure ongoing sanctions screening, record-keeping and governance. Effective compliance protects both the organisation and the national interest, upholding the UK’s role in promoting global security and rule of law.