Fragmented and incoherent: the UK’s sanctions policy Contents


1.Sanctions are essential to UK foreign policy, providing key levers by which the Government can exert pressure on terrorist groups, rogue regimes and individuals connected to those regimes. They also enable the UK and its partners to demonstrate solidarity with one another and to support the rules-based international system in the face of threats and unacceptable behaviour. A robust, effective and coherent sanctions policy is therefore indispensable to the UK’s foreign policy and national security strategy.

2.The UK adopts sanctions primarily through the UN and the EU, with about two thirds of its current sanctions regimes deriving from the EU.1 Leaving the European Union will thus bring about a seismic shift in how the UK adopts, imposes and implements economic and financial sanctions. For this reason, Parliament passed the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) which provides the legal foundation for the UK to have an autonomous sanctions policy.2 Since that Act became law in May 2018, the Government’s activity on sanctions has been focused on ensuring that the UK will be legally able to maintain existing EU sanctions under UK law, even in a no-deal exit scenario.

3.In our May 2018 report, Moscow’s Gold: Russian Corruption in the UK, we welcomed the introduction of SAMLA and called on the Government to consider broadening its approach to sanctions by including individuals closely connected to hostile regimes.3 The Government did not address this recommendation in its response to that report.4 This report picks up many of the themes we initially explored in Moscow’s Gold, and also explores some of the issues we first identified in our March 2018 report on Global Britain.5

4.The Committee would like to thank all the individuals and organisations who submitted written evidence to this inquiry, and all of the witnesses who gave oral evidence.6

1 In its written submission to this inquiry, the FCO said that “The UK currently implements sanctions agreed through the UN, the EU and the Organisation for Security and Cooperation in Europe (OSCE). The UK maintains 38 multilateral sanctions regimes: 10 UN, 21 EU, 5 mixed UN/EU, and 2 OSCE regimes. In total, 1488 individuals and 640 entities are subject to sanctions under these regimes (as of 20 December 2018).” Foreign and Commonwealth Office (FSP0015), para 12.

3 Foreign Affairs Committee, Eighth Report of Session 2017–19, Moscow’s Gold: Russian Corruption in the UK, HC 932, para 31

4 Foreign Affairs Committee, Twelfth Special Report of Session 2017–19, Moscow’s Gold: Russian Corruption in the UK: Government response to the Committee’s Eighth Report, HC 1488

5 Foreign Affairs Committee, Sixth Report of Session 2017–19, Global Britain, HC 780

6 We took oral evidence from Tom Keatinge (Royal United Services Institute), Dr Justine Walker (UK Finance), William Browder (CEO, Hermitage Capital Management), Lord Barker of Battle (Executive Chairman, En+ Group), William McGlone (Latham and Watkins, LLP), Maya Lester QC (Brick Court Chambers), The Rt Hon Sir Alan Duncan MP (Minister of State at the Foreign and Commonwealth Office) and Mr Qudsi Rasheed (Head of Sanctions, Foreign and Commonwealth Office).

Published: 12 June 2019