Understanding sanctions in the UK
Sanctions in the UK fall under the authority of several different departments. The Foreign & Commonwealth Office (FCO) is responsible for negotiating international sanctions and has overall responsibility for the UK’s policy on sanctions and embargoes. Meanwhile, HM Treasury (HMT) is the entity responsible for making designations under UK domestic financial sanctions and for the implementation and enforcement of all financial sanctions in the UK (through its subordinate agency, the Office of Financial Sanctions Implementation). In addition, the Department of Business, Innovation and Skills implements some trade sanctions and embargoes. Sanctions imposed by the UK can consist of a variety of punitive measures, but most common are financial sanctions, import/export and travel bans, and embargoes.
The UK follows international procedures to implement international sanctions. First, the UN imposes sanctions through Security Council Resolutions. The EU then takes a Common Position and, where appropriate, will introduce an EU regulation that is directly applicable to member states. Lastly, where necessary, the UK introduces or amends secondary licensing and enforcement legislation.
Types of Sanction
Arms embargoes: these ban either exporting or importing military arms between the UK and a sanctioned country. Arms embargoes apply to items on the UK Military List and certain other items that fall under Military End-Use Control. The Export Control Organisation (ECO), part of the Department for Business, Innovation and Skills, is responsible for regulating the goods covered by an arms embargo, as well as for administering exemption licenses.
Import bans: under certain circumstances, HMT allows UK firms to export certain goods to a sanctioned country but will not allow goods that were manufactured there to be imported to the UK. For example, the UK currently bans imports from Syria and, until recently, banned those from Iran.
Export bans: HMT is authorised to ban firms and individuals from exporting goods to a sanctioned country. If a firm or individual violates the sanction without being granted a special license, they can face severe penalties.
Financial sanctions: a financial sanction can consist of various penalties, including the prohibition of transferring funds to certain countries and the freezing of accounts and assets. There are also specific financial sanctions that may prohibit individuals from providing financial support or services for citizens of a sanctioned country.