UK Financial Sanctions: What businesses need to know + countries subject to sanctions
(S,P) Get a high-level overview of sanctions that apply and links to the latest regulations
Introduction
Financial sanctions are restrictions put in place by the UN or UK to achieve a specific foreign policy or national security objective.
They can:
limit the provision of certain financial services
restrict access to financial markets, funds and economic resources.
Financial sanctions are generally imposed to:
coerce a regime, or individuals within a regime, into changing their behaviour (or aspects of it) by increasing the cost to them to such an extent that they decide to cease the offending behaviour;
constrain a target by denying them access to key resources needed to continue their offending behaviour, including the financing of terrorism or nuclear proliferation;
signal disapproval, stigmatising and potentially isolating a regime or individual, or as a way of sending broader political messages nationally or internationally; and/or protect the value of assets that have been misappropriated from a country until these assets can be repatriated.
Actors involved in making and implementing sanctions
The United Nations (UN) imposes financial sanctions and requires member states to implement them through Resolutions passed by the UN Security Council. You can read more about the UN’s work on financial sanctions on their website:
https://www.un.org/sc/suborg/en/sanctions/information
The United Kingdom (UK) imposes financial sanctions. These are implemented through a combination of statutory instruments (UK regulations) and primary legislation:
Sanctions and Anti-Money Laundering Act 2018 (Sanctions Act)
Counter Terrorism Act 2008 (CTA 2008)
Anti-Terrorism, Crime and Security Act 2001 (ATCSA 2001)
Types
Financial sanctions come in many forms as they are developed in response to a given situation. The most common types of financial sanctions used in recent years are:
Targeted asset freezes: these apply to named individuals and entities restricting access to funds and economic resources. Someone subject to an asset freeze in the UK will be listed on OFSI’s consolidated list: https://www.gov.uk/government/publications/financial-sanctions-consolidated-listof-targets
Restrictions on a wide variety of financial markets and services: these can apply to named individuals and entities, specified groups, or entire sectors. To date these have taken the form of:
investment bans
restrictions on access to capital markets
directions to cease banking relationships and activities UK financial sanctions
requirements to notify or seek authorisation prior to certain payments being made or received
restrictions on the provision of financial, insurance, brokering or advisory services or other financial services.
Directions to cease all business: these will specify the type of business and can apply to a specific person, group, sector or country.
Who needs to comply with financial sanctions
UK financial sanctions apply to all persons within the territory and territorial sea of the UK and to all UK persons, wherever they are in the world. This means that:
All individuals and legal entities who are within or undertake activities within the UK’s territory must comply with UK financial sanctions that are in force.
All UK nationals and legal entities established under UK law, including their branches, must also comply with UK financial sanctions that are in force irrespective of where their activities take place.
Zimbabwe
Zimbabwe is currently subject to UK financial sanctions. This document provides a current list of designated persons.
Afghanistan is currently subject to UK financial sanctions. This document contains a current list of designated persons.
The Central African Republic is currently subject to UK financial sanctions. This document provides a current list of designated persons.
UK financial sanctions are in place for persons involved in the proliferation and use of chemical weapons. This page contains the current list of designated targets.
Iran relating to nuclear weapons This page contains the list of asset freeze targets, listed because of proliferation-related activity in Iran. It also contains information on regulations.
Libya Libya is currently subject to UK financial sanctions. This document contains a current list of designated persons and information on relevant regulations
Syria Syria is currently subject to UK financial sanctions.This document provides a current list of designated persons.
Yemen Yemen is currently subject to UK financial sanctions. This document contains a current list of designated persons.
Russia The Russia (Sanctions) (EU Exit) Regulations 2019
Downloads
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