On 27 April 2021, the United Kingdom implemented a new Global Anti-Corruption Sanctions Regime, enhancing its existing Global Human Rights Sanctions Regime, which came into force in July 2020. The new Global Anti-Corruption Sanctions Regulations 2021 enable the UK Foreign Secretary to impose asset freezes and travel bans on designated individuals and entities linked to certain corrupt activities, and criminalises the breach of those sanctions within the UK, as well as any breach by any UK individual or UK entity wherever located.

A recently published article published on DJSupra examines the scope and the content of the new regulations and draws a provisional conclusion. According to the authors, the new UK’s Global Anti-Corruption Sanctions Regime would be a further step by the UK on its path to forge its own post-Brexit sanctions policy. It would mirror the approach taken by its international partners, the US and Canada, both of which already have systems in place that impose sanctions on people and entities based on allegations of corruption.

The authors conclude that the introduction of corruption for the first time in a sanctions regime would mark a significant change in the UK. Therefore, companies would need to be more alert when conducting due diligence of customers and third parties. Although the UK government has stated that the regime targets individuals, not countries, the authors assume that the UK’s practical approach appears to be heavily influenced by its relations with other countries: Several of the individuals to whom the regulations have applied so far would be elected persons, including legislators and government officials. This would show that the UK is prepared to take an aggressive stance in relation to public corruption, by openly condemning elected officials.