UK Cross-Government sanctions review findings and action plan published

The review, launched in October 2024, was led by the Foreign, Commonwealth and Development Office in collaboration with HM Treasury, the Department for Business and Trade, the Department for Transport, HM Revenue and Customs and the National Crime Agency.

Aims

The aims of the review were to:

• improve and facilitate sanctions compliance;
• increase the deterrent effect of enforcement; and
• invigorate the cross-Government toolkit, ensuring access to the right capabilities, capacity, powers, and actionable intelligence to take robust enforcement action against those who seek to evade sanctions.

Themes arising from external engagement

The review's findings were informed by insights from industry experts, international partners, academics, and others.

The policy paper identifies 14 key themes arising from HMG's external engagement:

1. Recognition that different sectors are at different levels of maturity with sanctions, and that government communications and engagement should reflect that.
2. There is a premium on direct engagement between government and industry, it has the highest impact when it comes to increased compliance.
3. The UK Government sanctions brand should be consolidated and the digital footprint developed to improve the accessibility of sanctions guidance and notifications. 
4. Scope to improve guidance, bridging gaps in unclear regulations and providing more tailored support for industries who don’t have specialised compliance advice.
5. Improvements to the ownership and control model to aid compliance and reduce risks of competitive disadvantage to UK industry.
6. Publicise enforcement action, underpinned by a well understood cross-government enforcement strategy to target the most severe penalties to the most significant breaches, maximising the deterrent effect. 
7. Greater clarity on how sanctions action delivers the foreign policy purposes and the direction of desired behaviour change.
8. Join up across government departments, maximising the intelligence and analysis from different elements of the system. 
9. Recognition of investment in resource and expertise but noted that retention of staff and long-term relationships were paramount. 
10. Opportunities to collaborate with the private sector throughout the sanctions policy cycle.
11. Government to consider how it shares information externally, making the most of established or new information sharing fora.
12. Opportunity for new or reinforced avenues for reporting welcomed, although stakeholders unsure over worth of incentive schemes. 
13. Look to remove or ameliorate impediments to prosecutions and explore additional obligations on ‘enablers’ who protect designated individuals. 
14. Creative and bold ideas for reducing administrative burden would be welcomed from a broad array of stakeholders, with hope that resource could be reinvested into more complex compliance.

Further detail on these themes is set out at Annex 2 of the review.

Actions

The report identifies key actions to be taken by Government. HMG has committed to implementing the following 10 actions in the 2025/2026 financial year.

Compliance

• Deliver measures to provide further clarity on the concepts of ownership and control (which pose challenges to compliance).
• Create additional guidance for, and increase engagement with, sectors less familiar with sanctions compliance.
• Deliver a comprehensive update to sanctions pages and statutory guidance on GOV.UK to make it clearer and better structured.
• Consolidate the UK Sanctions List and the Consolidated List of asset freeze targets into a single sanctions list for all UK designations.

Deterrence

• Regularly publish sanctions enforcement actions and disruptions to take advantage of "teachable moments". This will help industry learn from remedial actions.
• Publish a government-wide sanctions enforcement strategy to assist industry understand the range of non-compliance and possible enforcement consequences.
• Develop an early civil settlement scheme for breaches of financial sanctions for public consultation. Quicker resolution of civil financial sanctions cases would aid deterrence, ensure efficiency and lessen the burden from enforcement action.
• Develop an accelerated civil penalty process for certain financial sanctions breaches for public consultation to deliver more efficient and proportionate enforcement outcomes and drive compliance with reporting and licensing requirements, while freeing up resources for more complex breaches and reduce administrative burden on industry.

Toolkit

• Explore ways to clarify reporting requirements and channels, including a single reporting point for suspected breaches.
• Update the Public Interest Disclosure (Prescribed Persons) Order 2014 to ensure that workers who disclose prescribed information relating to breaches of financial, transport, and certain trade sanctions to the relevant government departments can qualify for whistleblowing protections.

In the longer term, the Government has also committed to:

• exploring options for more effective "join up" on intelligence, including the merits of a new joint sanctions intelligence function.
• considering the introduction of sanctions end-use licensing controls for exports with high risk of sanctions diversion.
• supporting interested Overseas Territories to implement civil enforcement powers.
• enhancing transport powers to restrict the movement of targeted aircraft.

If you have any questions about how these actions might affect your business, feel free to reach out to one of our sanctions experts.

Our team

Fieldfisher's experienced multi-disciplinary sanctions and export control team includes lawyers who have negotiated and drafted EU and UN sanctions regimes in Government and regularly provide sanctions advice to businesses operating around the world in a wide variety of sectors. We work closely with US partners to provide coordinated, comprehensive and practical advice to help business understand and manage the impact of sanctions.

For more information please contact Andrew Hood (Partner, International Trade).

* The contents of this notice do not constitute legal advice and are provided for general information purposes only.