Sanctions and Export Controls

Cyber Sanctions: what are they, and are they here to stay?

Sanctions in the UK

Sanctions (including travel bans[1] and asset freezes) are a tool of foreign policy where the UK, as an EU member, not only implemented EU laws[2], but also played a leading role in making them.

While the policy lead for sanctions lies with the Foreign Office, the responsibility for enforcement lies with the Home Office (for travel bans) and HM Treasury, specifically the Office for Financial Sanctions Implementation (OFSI), which oversees a system of financial penalties for breaches of financial sanctions[3].

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Magnitsky Sanctions in the UK: Who are the Targets?

‘Gross violations’

What does the first list of ‘designated persons’ under the UK’s Magnitsky sanctions regime tell us about how they will be used? It is, perhaps deliberately, a mixed bag of targets, a set of 49 individuals and organisations from four different countries, associated with some of the UK’s highest-profile foreign policy issues. Most, but not all, of them also seem designed to fit the category of ‘gross violation of human rights’ in the enabling Act (the Sanctions and Anti-Money Laundering Act 2018 (SAMLA)) – very broadly, the torture by state officials of those who expose corruption or promote human rights. Indeed, 25 of the targets, a bare majority are said to be associated with the case of Magnitsky himself, who died in a Russian prison in 2009, after making allegations of corruption.

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Sanctions, Frozen Assets, Disclosure Risks – The Responsibilities Corporates Have Under Law

BCL partner, John Binns writes for The Treasurer explaining that an awareness of financial crime and the responsibilities corporates have under law is an essential part of risk management.

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