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ARTICLE · 10 NOVEMBER 2026

Anti-corruption Sanctions: Key Takeaways

DLA Piper
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Economic sanctions targeting corrupt individuals represent a distinct foreign policy tool that differs from both traditional anti-corruption legislation and geographic sanctions. This analysis examines how the United States, United Kingdom, and European Union deploy anti-corruption sanctions against public officials and their enablers, exploring the unique compliance challenges these measures create for businesses operating in high-risk jurisdictions.

GlobalGovernment, Public Sector
Katie Palms
Katie Palms
Isabel Fincham
Isabel Fincham
Lydia Rogers
Lydia Rogers

In recent years, economic sanctions have received significant attention in connection with countries such as Russia, North Korea, and Iran. However, economic sanctions may also be deployed against individuals, including public officials, who the sanctioning state perceives as engaging in corrupt behavior.

These "anti-corruption" sanctions differ from "geographic" sanctions in that they are punitive – as noted, they focus on specific persons perceived as engaging in corrupt behavior, not the economic activity of a broader collection of persons and sectors that the sanctioning state may wish to reshape.

At the same time, anti-corruption sanctions also differ from traditional anti-corruption legislation, in that they are imposed as new laws or regulations by foreign offices – not as penalties by courts or prosecutors following breaches of pre-existing laws or regulations.

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