On 19th September, RUSI published an Occasional Paper which offers recommendations adapted from initial discussions by the RUSI Task Force on the Future of UK Sanctions Policy regarding what UK sanctions could look like after Brexit. It starts by saying that a potential gap has been addressed in the form of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). In addition, civil servants have devoted significant resources to rolling over existing EU sanctions into UK law by creating the necessary statutory instruments and replicating the vast majority of EU sanctions designations under this new legal regime. However, while the technical and legal work has been completed, it says, an open question remains: what will the UK’s post-Brexit sanctions policy be? It provides 3 primary recommendations – develop a strategic approach; it should endeavour to use sanctions not only as a tool for advancing foreign policy objectives but also to respond to recognised national security threats, such as those presented by serious and organised crime and those which undermine the integrity of the UK’s financial system; and outreach and guidance to the private sector should be extended if UK-only sanctions are to be effective and implemented without unintended consequences, and this includes providing clear guidance on licensing for NGO and humanitarian actors.
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