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Deter, Disrupt and Demonstrate

Author: Dr. Ellen Sanchenko  23 February 2024

Ellen Sanchenko assesses the UK government’s latest sanctions implementation update.

The UK government’s “Deter, Disrupt and Demonstrate – UK sanctions in a contested world. UK sanctions strategy’’ provides an update on the implementation of sanctions under the UK sanctions regime. 

It largely reiterates points that have already been covered in previously-published material, such as Office of Financial Sanctions Implementation guidance documents. But the fact that the government has decided to publish it can be seen as an indicator that it sees sanctions as continuing to play a very important role – and arguably an increasingly important one – in the international arena.

While the document covers all 36 current UK sanctions regimes, its main focus is on Russia. This is not particularly surprising, given the unprecedented scale of the sanctions imposed on Russia since the invasion of Ukraine just over two years ago.

It states that the UK has sanctioned over 96% of the goods that the UK traded with Russia in 2021. As of October 2023, over £22 billion of Russian assets were reported frozen as a result of financial sanctions. A total of 29 banks, accounting for over 90% of the Russian banking sector, have been sanctioned.

The document emphasises the importance to sanctions implementation and enforcement of inter-relationships between the various departments, agencies and regulators. To take an example, the new Office of Trade Sanctions Implementation (OTSI) in the Department for Business and Trade will be responsible for the implementation and civil enforcement of certain trade sanctions. It will work in close collaboration with HM Revenue and Customs, which enforces sanctions on the import and export of goods at the UK border.

Tackling sanctions circumvention is highlighted as a particular focus for the UK and its G7 partners. The document outlines how the government is working with third countries on the risks of circumvention. One way this is being done is through expanding the network of sanctions practitioners in UK diplomatic missions, with the aim of strengthening relationships with third countries so that increased collaboration can result in intensified efforts to tackle such circumvention.

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Dr. Ellen Sanchenko

Associate Solicitor

ellen.sanchenko@rahmanravelli.co.uk
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Ellen works on notable white-collar crime cases and other multinational, high-value investigations. She is also known for her asset recovery, commercial litigation, civil fraud and sanctions case work.

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