Post-Brexit sanctions—the road ahead

• Guidance: understanding the legislative and regulatory changes.
• Current policy: key drivers.
• UK human rights sanction regime.
• International partnerships and alliances: unique challenges.

When the Brexit ‘implementation’ period ended on 31 December 2020, the UK’s new autonomous sanctions regime entered legal effect. While the long-term consequences of these new regulations remain to be seen, activity in Britain’s sanctions landscape both before and since its departure from EU-led regulatory practices have confirmed the intentions of the Office of Financial Sanctions Implementation (OFSI) to keep sanctions a lasting and effective regulatory tool in the UK.

OFSI was remarkably active both in the run-up to and during the implementation period and remained so in the first months of the new regime taking effect. It has published a significant amount of guidance materials targeted at helping firms to understand the legislative and regulatory changes, and issued the first UK general licence, under the Russian sanctions regime. The latter