Sanctions Compliance: A Challenge For Us All

Read part one here, titled 'Sanctions and Brexit: Changes Coming to UK Sanctions Laws – Deal or No Deal'.

'Targeted' sanctions?

It is a pernicious feature of sanctions laws that they affect far more people than they target. Traditionally, the imposition of sanctions was something the leaders of one state did against the leaders of another; the idea of targeting them at 'designated persons' was to avoid the effects that comprehensive sanctions had on the innocent populations of 'enemy' countries. Now, the principal effect of, say, an asset freeze on a Russian oligarch is to impose criminal penalties anyone who deals with his assets, or who provides economic resources to him or for his benefit. That creates a risk not just for financial institutions, but for literally anyone, individuals and businesses, operating or based in the UK.