UK Government Publishes Global Human Rights Sanctions Regulations 2020

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Shearman & Sterling LLPHM Treasury has published the Global Human Rights Sanctions Regulations 2020, a new piece of U.K. legislation designed to target those involved in serious violations of human rights. The Regulations come into force on July 6, 2020. They apply to relevant conduct by any person across the whole of the U.K. but also have extra-territorial effect, additionally applying to conduct by U.K. persons (including U.K. incorporated companies and overseas branches of such companies) outside the U.K. and by any person in the territorial sea adjacent to the U.K.

The Regulations seek to deter activity which, if carried out by or on behalf of a State in that State, would seriously violate an individual's right to life, right not to be subjected to torture or degrading treatment or right to be free from slavery. Where these activities are carried out by non-State actors, they may not be captured by international human rights law. Under the Regulations, the U.K. Government is able to designate individuals, entities or organizations as being subject to sanctions under the regime, including asset-freezes and travel bans. A list of designated persons is available on the U.K. Government website. Firms that maintain accounts or hold any funds or other economic resources for or on behalf of any of the persons set out on the U.K. Government's website should freeze those accounts, refrain from dealing with the funds or assets, report any findings to the Office of Financial Sanctions Implementation and provide any information concerning the frozen assets that OFSI requests. The U.K. Government has also published guidance on the Global Human Rights regime, providing further detail on the purpose of the regime and the offences and penalties contained therein.

The Regulations have been published under the U.K. Sanctions and Anti-Money Laundering Act 2018, the majority of which came into force on November 22, 2018. The SAMLA was recently amended to enable the U.K. Government to implement international sanctions following the U.K.'s departure from the EU.

View the Global Human Rights Sanctions Regulations 2020.

View the Explanatory Memorandum to the Global Human Rights Sanctions Regulations 2020.

 View the U.K. Government guidance on the Global Human Rights Regime.

View details of the amendments to the SAMLA.

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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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