UK Finance – Sanctions publications

Latest Sanctions Webinars:

UK Finance response to the UK Foreign Affairs Committee Inquiry to Explore and Evaluate the Different Options for the UK’s Approach to Sanctions Policy Post Brexit
UK Finance briefing paper – December 2018

We thank the Committee for the opportunity to submit written evidence to its inquiry to explore and evaluate the different options for the UK’s approach to sanctions policy after leaving the EU. In preparing this response, we have drawn on the expertise of our well-established sanctions panel of European and international banks. This panel works extensively on mechanisms to improve the effectiveness of sanctions compliance and undertakes significant engagement with EU and US counterparts. At an international level, we have been working closely with the United Nations, the EU and UK Government officials on a range of sanctions implementation matters, such as: the impact of the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA), US specific sanctions on Russia, humanitarian issues and mitigating the risk of North Korean sanctions evasion. Furthermore, we provide expert input into a number of international groupings and currently chair the European Banking Federation Sanctions Expert Group.

The EU Blocking Regulation – Issues and Considerations for the Financial Services Sector
UK Finance briefing paper – July 2018

This UK Finance briefing paper has been prepared by our Sanctions Panel to help advance dialogue with EU authorities on the practical aspects associated with implementation of the updated EU Blocking Regulation. In specific, the paper sets out the challenges of complying with divergent and conflicting US – EU cross-border sanctions obligations and key areas of concern for natural and legal persons. Over recent weeks we have worked extensively to set out the direct conflict of law scenarios that our members may potentially face. We continue to urge the European Commission and Member States to ensure identified conflicts are reasonably addressed within the forthcoming European Commission guidance which will accompany the introduction of the updated Blocking Regulation.
The Regulations comes into force 06 August. Read more…

Dusting Off the EU Blocking Statute – An Effective Measure against US Secondary Sanctions?
Dr Justine Walker blog – May 2018

Our last blog dealt with how we are entering unchartered territory following the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA). As set out in our webinar yesterday, the Trump administration has geared up for a significant diplomatic campaign to convince companies to exit Iran. Read more…

The Iran Nuclear Deal – Entering Unchartered Territory
Dr Justine Walker blog – May 2018

Over recent months, UK Finance has written on the escalating transatlantic divergence in sanctions policy and the impact for our members in assessing their sanctions compliance posture and risk exposure. The impact of last night’s US withdrawal from the international nuclear deal, commonly known as the Joint Comprehensive Plan of Action (JCPOA), should not be underestimated. Read more…

Russia – the sanctions impact of escalating geopolitical tensions
Dr Justine Walker blog – April 2018

Last Month UK Finance blogged about the dynamic geopolitical environment which has resulted in the international sanctions compliance landscape changing faster than ever before.  Our message was that given current world events it would be unlikely that Governments will cease their reliance on sanctions as the “go to” instrument. Over recent weeks’ no-where has this been more evident than the response to the deteriorating diplomatic relationship between the West and Russia. Read more…

The shifting sands of sanctions policy
Dr Justine Walker blog – March 2018

The dynamic geopolitical environment has resulted in the international sanctions compliance landscape changing faster than ever before. As an indication as to the scale of change since last summer we have seen increased sanctions on Iran, Syria, Russia, Venezuela and North Korea as well as a roll back of the Cuban sanctions relief provided under President Obama and the lifting of long standing sanctions on Sudan. Read more…

Public Bill Committee on the Sanctions and Anti-Money Laundering Bill
UK Finance Written Submission – March 2018

We are pleased to respond to this call for written evidence to the Public Bill Committee on the Sanctions and AntiMoney Laundering Bill (“the Bill”). At the outset, we wish to highlight that UK Finance and our members recognise that decisions on whether to impose sanctions as a foreign policy and national security tool is a matter for the Government. As such, our response is aimed at informing the viability of implementation to ensure the future application of UK sanctions measures can achieve their intended objectives whilst being practical to apply. Read more…

Impact of Brexit on the Future Application of UK Sanctions
UK Finance Parliamentary Briefing for Peers – December 2017

This is a briefing note from UK Finance focused on the impact of Brexit on the future application of UK sanctions. The note outlines the International Sanctions compliance landscape in which UKF members operate and our key observations of the new Legislative Framework the UK will use post Brexit to implement Sanctions – the Sanctions and Anti-Money Laundering Bill. Read more…


House of Lords EU External Affairs Sub-Committee inquiry on sanctions policy after Brexit
UK Finance Written Submission – July 2017

Our response is intended to set out, on behalf of members, themes which are viewed as particularly important to the overall effectiveness and implementation of the UK’s sanctions regime as it moves ahead with developing the legislative framework. In addition, the main points that members would like UK Finance to reinforce are specifically categorised. Read more…