GlobalUnited Kingdom 

On 26 April 2021, the UK launched the Global Anti-Corruption sanctions regime against individuals and organisations responsible for serious international corruption. The first wave of sanctions designations includes 22 individuals who have been added to the UK Sanctions List.

The UK has launched the Global Anti-Corruption sanctions regime pursuant to the Global Anti-Corruption Sanctions Regulations 2021 (the Regulations). The Regulations are made under the Sanctions and Anti-Money Laundering Act 2018 and provide for the freezing of funds and economic resources of certain persons, entities, or bodies involved in serious corruption.

The Global Anti-Corruption sanctions regime builds on the UK’s Global Human Rights sanctions regime that was established in July 2020 and has resulted in the UK imposing sanctions on 78 individuals and entities involved in serious human rights violations, including from Myanmar, Belarus, China, and Russia.

In a written statement to parliament, the UK Foreign Secretary said the new Global Anti-Corruption sanctions regime would “ensure that the UK is not a safe haven for those involved in serious corruption, including those who profit from it”.

The first wave of designations under the Regulations target 22 individuals involved in notorious corruption cases in Russia, South Africa, South Sudan, and Latin America, including:

  • Those involved in the diversion of $230 million of Russian state property through a fraudulent tax refund scheme uncovered by Sergei Magnitsky.
  • Ajay, Atul, and Rajesh Gupta and their associate Salim Essa, for their roles in corruption in South Africa.
  • Sudanese businessman Ashraf Seed Ahmed Hussein Ali, widely known as Al Cardinal, for his involvement in the misappropriation of significant amounts of state assets.
  • Several individuals involved in corruption in Latin America, including facilitating bribes to support a major drug trafficking organisation and misappropriation.

The 22 individuals included in the first wave of designations have been added to the UK Sanctions List. The full list of designated persons is accessible here.

The Regulations impose asset freezes on the designated persons (including a prohibition on making funds available, directly or indirectly, to or for the benefit of designated persons), and travel bans targeting the designated persons. The Regulations make it a criminal offence to contravene the financial sanctions prohibitions or to seek to circumvent the prohibitions.

This regime replaces the Misappropriations (Sanctions) (EU Exit) Regulations 2020 regime concerning misappropriation of state funds from any country outside the UK.

Next Steps 

The new regime allows the UK to impose sanctions on individuals and organisations unilaterally, not just alongside the United Nations or the EU. Until this year, the UK has previously had to act in concert with the EU with regards to sanctions, but the introduction of this autonomous new sanctions regime is a clear indicator of the UK's intention to adopt a more independent sanctions policy post-Brexit and to use its sanctions policy as a geopolitical tool. By Hogan Lovells - Aline DoussinImogen Brooks and Iris Karaman, Lexology