On October 21, 2020, the UK Foreign, Commonwealth and Development Office’s Sanctions Unit hosted a webinar to explain how UK sanctions policy and compliance will operate when the Brexit transition period ends.
EU sanctions will no longer apply in the United Kingdom after 11pm GMT on December 31, 2020. The UK’s new sanctions regime will come into force under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) from that time. Existing sanctions regimes will either be addressed under SAMLA or, in the case of some EU sanctions, continue as retained EU law under the EU (Withdrawal) Act 2018. UN sanctions also will be implemented in UK domestic law.
Whilst the new UK sanctions regime will broadly replicate existing EU sanctions measures, there will be divergence in certain areas.
Sanctions policy aside, the degree of divergence of approach in the architecture of the UK’s new legal framework for sanctions brings with it the potential to create sanctions compliance difficulties for companies operating in both the United Kingdom and European Union that will be required to comply with both regimes. Affected businesses should carefully analyse the requirements of the UK and EU sanctions regimes to ensure that they remain compliant when the Brexit transition period ends.
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