The regime will not cover corruption - as with UK GHR sanctions, the name ?Magnitsky? has not directly been used.

The individual designations are not yet known but could align with the recent UK listings, covering events such as the killings of Russian lawyer Magnitsky and Saudi journalist Jamal Khoshaggi.

• Why an independent sanctions programme?

Although the EU has targeted perpetrators of human rights abuses in the past, it has done so on a case-by-case and country-specific basis. According to Josep Borrell, the EU High Representative for Foreign Affairs and Security Policy:

?We need a global regime to gain more flexibility to go after the perpetrators regardless of where they are and dispense us from having to set up a specific legal framework each time for each specific case.?

This reflects the wider shift to thematic sanctions since 2016 (e.g. for terrorism, chemical weapons, cyber-attacks) with the view to cover perpetrators in any geographical location in the world.

It is worth noting that the GHR regime will not replace the existing country regimes where human rights abuses are targeted. For instance, the current Belarus programme, which sanctions the government following the highly disputed August election, will not be integrated to the human rights sanctions framework.

• Adopting human rights sanctions: consensus or qualified majority?

The question of human rights sanctions has revived the debate on qualified majority voting (QMV) in the Council on issues of foreign policy[1]. If this regime intends to ?go swiftly after the perpetrators? of abuses, as Mr Borrell hopes, it will require greater flexibility than the procedure currently allows. Proposals to adopt qualified majority have already been put forward by Borrell for implementing the EU's Action Plan to support democracy and human rights, but these have remained unanswered.

The same position was strongly endorsed by Ursula von der Leyen, president of the EU Commission, in her State of the Union speech which urged member states to move to qualified majority ?at least for human rights and sanctions implementation?. Most recently, and only days after this speech, Cyprus? refusal to approve sanctions against Belarus led Borrell to admit the credibility of the EU was at stake over the issue of sanctions adoption.

There is still uncertainty around whether the current proposal includes QMV or maintains the consensus rule[2]. However, although this position seems to be shared by some member states, at this time, ironically it is unlikely to reach the unanimity it needs to be adopted.

• From across the Channel: the UK point of view

From a UK perspective, the new regime is likely to prove a challenge. As the UK is still subject to EU law until the end of the transition period, including on sanctions, the new regulation will need to be implemented during an already exceptionally busy parliamentary timetable due to the upcoming end of the transition period as well as Covid-19-related extraordinary legislation.

The UK government has not committed to issuing a new autonomous regulation in that period, which will likely lead to the new EU-derived regulation having to be retained after 31 December 2020.