UK Announces New Global Anti-Corruption Sanctions Regime

Pillsbury - Global Trade & Sanctions Law

Pillsbury - Global Trade & Sanctions Law

On April 26, 2021, the UK announced a new global anti-corruption sanctions regime and has imposed sanctions on 22 people whom the UK Government has reasonable grounds to suspect have been involved in serious corruption. Under the new Global Anti-Corruption Sanctions Regulations 2021 (SI 2021/488), those designated will be subject to an asset freeze and travel ban.

The Global Anti-Corruption Sanctions Regime has been introduced under the UK Sanctions and Anti Money Laundering Act 2018. The Sanctions Act was introduced to enable the UK to implement sanctions after the UK’s departure from the EU. Section 1 of the Sanctions Act enables the UK Government to introduce sanctions regimes for the purposes of compliance with UN obligations and other international obligations, as well as for a number of other purposes which include: furthering the prevention of terrorism; national security; promoting international peace and security; promoting compliance with international human rights law and respect for human rights; furthering foreign policy objectives; and promoting respect for democracy, the rule of law and good governance.

A press release from the UK government stated that “This new regime will allow the UK to combat serious corruption, in particular bribery and misappropriation. It will promote effective governance, robust democratic institutions and the rule of law—demonstrating our power as a force for good around the world.”

Those persons designated by the UK under the Global Anti-Corruption Sanctions Regime as of April 26, 2021 include:

  • 14 Russian nationals;
  • 3 Indian business persons;
  • 1 Guatemalan official, 1 South African business person, 1 Sudanese business person, 1 Nicaraguan official, and 1 Honduran Congress person.

See the full list here. Organizations caught by the new regime should confirm that they do not engage in business dealings with any of the sanctioned parties. The UK Government has issued guidance on the Global Anti-Corruption Sanctions Regime, and the U.S. press release on the new regime can be found here.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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