The UK is introducing its new sanction regime in preparation for a future outside of the EU. As of 11pm on the 31st December 2020, financial services firms must comply with the UK’s Sanctions and Anti-Money Laundering Act 2018 (the “UK Sanctions Act”). Although very similar to the existing requirements, the updated sanctions list will consist of designations the UK has chosen to carry over from the EU regimes, as well as those that the UK is obliged to implement under UN regimes.
The UK Sanctions Act will have a consolidated list of financial sanctions of those subject to asset freezes, and a separate list for those subject to restrictions on financial markets and services. Financial services firms operating in the UK should consider reviewing their sanctions programs in light of the new requirements. Details of the UK Sanctions Act are available here.