Sanctions Enforcement – Recent Trends

Theresa May, UK Prime Minister, in a speech last month at the Munich Security Conference, reaffirmed the UK's commitment to sanctions post-Brexit, saying:

"We will look to carry over all EU sanctions at the time of our departure. And we will all be stronger if the UK and EU have the means to co-operate on sanctions now and potentially to develop them together in the future."¹

The practical mechanism for the UK's post-Brexit sanctions regime is working its way through the UK Parliament in the form of the Sanctions and Anti-Money Laundering Bill ("the Bill"), which passed its second reading in the House of Commons at the end of February. The Bill is designed to be the mechanism through which the UK is able to fulfill its international obligations to implement UN sanctions, and to update and amend sanctions in the future. The UK Parliament Joint Committee on Human Rights published its report on the Bill on 28 February, in which it expressed some concern at the broad