UK Sanctions Regimes: Post-Brexit Guide for Firms
In brief: UK sanctions regimes are the legal frameworks that create specific UK restrictions for countries, themes, sectors, people, entities, goods, and services.
Key points
- UK sanctions are not simply copied from EU lists after Brexit.
- Firms should check current UK sources for the specific regime and restriction.
- The file should record both list screening and matter-specific sanctions risk.
What are UK sanctions regimes?
UK sanctions regimes are the legal frameworks that set restrictions for specific countries, themes, sectors, people, entities, ships, goods, or services. Since Brexit, UK sanctions operate under UK law and may differ from EU measures.
Why this matters
A client may be clear on a name screen but still create matter risk because the work involves a sanctioned sector, restricted service, controlled goods, ownership links, or a high-risk jurisdiction.
What firms should check
- UK sanctions list and OFSI consolidated list.
- Ownership and control.
- Country and sector exposure.
- Services the firm is being asked to provide.
- Payments and third-party funders.
- Need for specialist advice or licence consideration.
Recordkeeping
Record the regime considered, sources checked, match review, client explanation, escalation, and decision.
This guide is general information for UK regulated firms. Sanctions change quickly, so always check the relevant official list or get specialist advice before making a client decision.