When the clock struck 11pm on 31 December 2020, the UK stopped applying EU sanctions and its own autonomous sanctions regime came into force. While the UK sanctions regime substantially does the same thing as the EU one, the lists of sanctioned entities may not be exactly identical. Importantly, UK sanctions may apply to non-UK sanctions and non-UK nationals, so it is important to stay up to date.

Brexit means that a company that operates in the UK and the EU is subject to at least two separate sanctions regimes. Therefore sanctions compliance has never been more important.

The UK has been preparing for this change for several years. This preparation includes the 2018 Sanctions and Anti-Money Laundering Act and the Global Human Rights Sanctions Regulations 2020. Additionally, over 30 statutory instruments have been laid to ensure a smooth transition to the new UK sanctions regime. 

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