January, 2021 - Sanctions: what does the post-Brexit landscape look like?
In our March Soundings, we foreshadowed how the sanctions landscape might look post-Brexit. Now that the transition period has ended and the UK has left the EU with a deal in place, we take a look at the new sanctions framework which came into force at 11pm on 31st December, 2020.
Following the UK’s exit from the EU, the Sanctions and Anti- Money Laundering Act 2018 (the Sanctions Act) enables the UK to transition existing EU sanctions into UK law. Perhaps most importantly the Sanctions Act also allows the UK to implement, update or lift sanctions. The UK also has in place a raft of other specific and subordinate legislation, regulation and orders. These regulations and orders deal with the separate specific areas such as terrorism, finance, export control immigration and all other areas that are required to be addressed by sanctions.