Hogan Lovells assists UK Finance with review of new UK sanctions regulations post-Brexit

In January 2020 the UK formally left the EU and moved into the agreed transition period. During this period all EU legislation has continued to apply in the UK and the corresponding UK statutory instruments previously used to transpose EU sanctions legislation have remained in effect.

When the transition period ends on 31 December at 11pm GMT, as agreed in the Withdrawal Agreement, EU sanctions legislation and regulations will cease to apply in the United Kingdom, and the UK's sanctions and embargoes programme will be implemented and administered under framework legislation known as the UK Sanctions and Anti Money Laundering Act (SAMLA) 2018.

The UK has been publishing the SIs that will be replacing the current EU-derived sanctions SIs (of which there are currently over 30, with more to come). Along with the sanctions SIs, nine amendment SIs have also been laid. These have enacted over 130 amendments to the SAMLA-derived SIs currently published.

The Review paper, published by UK Finance today with assistance from Hogan Lovells and other law firms, aims to review and compare the existing EU legislation with the new UK legislation. It assists in understanding the areas where the current requirements, language or general policy may have a different effect or interpretation post-Brexit, which has the potential to affect sanctions compliance obligations and processes.  

Jamie Rogers, partner at Hogan at Hogan Lovells, said: "Failure to comply with the latest sanctions requirements can put businesses at risk of hefty fines or reputational damage. The Review paper, released today by UK Finance, will help companies to prepare and adapt to the evolving sanctions landscape post-Brexit."

The review is available here, and will continue to be updated as more SIs and amendments are laid out.

The Hogan Lovells UK sanctions team includes Jamie Rogers (partner), Aline Doussin (partner), Louise Lamb (partner), Ellie Rees (associate) and Sarah McQuillan (associate) and Niharika Parshurampuria (trainee solicitor).