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Post-Brexit sanctions—the road ahead

02 July 2021 / Sarah Wrigley , Charlie Steele
Issue: 7939 / Categories: Features , Brexit
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Charlie Steele & Sarah Wrigley report on what to expect in the UK sanctions landscape post-Brexit
  • Guidance: understanding the legislative and regulatory changes.
  • Current policy: key drivers.
  • UK human rights sanction regime.
  • International partnerships and alliances: unique challenges.

When the Brexit ‘implementation’ period ended on 31 December 2020, the UK’s new autonomous sanctions regime entered legal effect. While the long-term consequences of these new regulations remain to be seen, activity in Britain’s sanctions landscape both before and since its departure from EU-led regulatory practices have confirmed the intentions of the Office of Financial Sanctions Implementation (OFSI) to keep sanctions a lasting and effective regulatory tool in the UK.

OFSI was remarkably active both in the run-up to and during the implementation period and remained so in the first months of the new regime taking effect. It has published a significant amount of guidance materials targeted at helping firms to understand the legislative and regulatory changes, and issued the first UK general licence, under the Russian sanctions regime. The latter clearly indicates the first of what will presumably be many post-Brexit

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