Fragmented and incoherent: the UK’s sanctions policy Contents


A robust, effective and coherent sanctions policy is indispensable to the UK as a global actor. The centrality of sanctions to UK foreign policy, national security and the functioning of the rules-based international system cannot be overstated. As it prepares to leave the EU, the UK must be ready to take responsibility for designing, implementing and enforcing its own sanctions.

Yet the Government does not have a clear strategy for sanctions. Little high-level thought appears to have been given to UK priorities for post-Brexit sanctions. Moreover, the Government’s failure to establish a clear legal view on whether the UK can independently sanction human rights abusers while still an EU member state, and its obfuscation on this issue in response to the Committee’s questioning, risk signalling that the UK is reluctant to use those powers. The Government must rectify this mistake by agreeing on a clear legal position and publishing it before the end of June.

The cross-Whitehall structures underpinning sanctions policy-making, implementation and enforcement are highly fragmented, further undermining strategic coherence and enabling departments to avoid taking responsibility. The Government should address this by appointing a Senior Responsible Officer for sanctions policy who will be personally accountable to the National Security Council.

The Foreign and Commonwealth Office also seems unwilling to acknowledge that it has a vital role to play in helping to keep the UK and our allies safe by cracking down on the laundering of dirty money. As this Committee has said in previous Reports, dirty money is a national security issue, especially in the light of London’s importance in the global financial system. It is simply not good enough for the Minister of State to assert that financial crime is “not quite” the Foreign and Commonwealth Office’s “patch”.

The Government has spent the last two years running as fast as it can just to stay in the same place. The time is right for a major review of the Government’s approach to sanctions at every stage. Without such a review, the UK runs the risk of allowing its sanctions policy to be dictated by the decisions of others. The UK must now seize the opportunity to become a global leader in sanctions policy. We hope the Government will take this warning to heart.

Published: 12 June 2019