One of the many unanswered questions associated with the United
Kingdom’s departure from the European Union on 31 January
2020 is the future use of sanctions as part of the United
Kingdom’s foreign policy playbook. From the time of Brexit on
31 January 2020 until 31 December 2020, OFSI has confirmed
that the United Kingdom will continue to apply all current EU
sanctions. At the end of this period, the United Kingdom will be
free to alter the extent to which the EU sanctions program is
applicable in the United Kingdom. As discussed further below, while
UK and EU officials have said they intend to coordinate as much as
possible on sanctions policy, the UK government has provided some
indication that it will use Brexit as an opportunity to carve its
own path and potentially strengthen its sanctions regime. A related
key question will be whether the United Kingdom will align itself
to the United States’ or the European Union’s policy on
Iran, or adopt its own position.
