As a member of the United Nations, the UK is required to implement sanctions imposed by the UN Security Council.  The UK currently implements those sanctions through EU regulations under the framework of the EU’s Common Foreign and Security Policy.  The UK also implements sanctions imposed autonomously by the EU through this framework.  Withdrawal from the EU will thus create a gap in the UK’s ability to meet its international obligations in respect of sanctions.  

The Sanctions and Anti-Money Laundering Act 2018, which received royal assent on May 23, 2018, is designed to address that gap.  The Act will broaden the UK’s power to impose sanctions after Brexit, enabling it not only to continue to comply with its international obligations, but also to expand its own sanctions regime, which is currently limited to terrorism legislation.  However, for now, the operative provisions of the Act are not in force.  Such provisions will require secondary legislation to be implemented, which will be scheduled around the Brexit timetable.

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