Growth and Developments in Sanctions in the UK
Learn about the developments in sanctions that the Chambers UK Bar team discovered during their research into this year's guide.
Sanctions targeting Russia and Belarus
It won’t be news to anyone that the US, EU and UK have introduced significant sanctions targeting Russia and Belarus, in addition to long-standing arrangements for other countries.
The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023 came into force in April, significantly expanding the scope of measures on imports from Russia. This followed a stream of announcements adding to the list of designated individuals and entities since the first measures were confirmed in February 2022.
Differences to the UK and the EU sanctions regimes
Also notable is the development of a UK sanctions regime as distinct from Europe, created by the Sanctions and Anti-Money Laundering Act 2018 or SAMLA.
The UK was known to be a leader among member states in the adoption of sanctions and it will be interesting to see how its approach could differ in future. Whilst the approach to listings is relatively coordinated between the US, UK and EU at a strategic level, there are key differences in the EU and UK frameworks – such as the scope of listings, and asset freezes – and these have added complexity to the situation.
Recent reports have revealed the number and scale of associated legal challenges, with the Foreign Office subject to at least 9 judicial reviews according to the Law Soc Gazette.
Although tougher rules on legal advice have caused a compliance headache for lawyers, the situation has also been a significant source of instruction for the Bar.