UK Cross-Government Review of Sanctions Implementation and Enforcement

By: Michael Ruck, Rosie Naylor, Petr Bartos, and Laura Scott

On 15 May 2025, the UK government published a policy paper summarising findings from a cross-government review of sanctions implementation and enforcement. The aim of the review was to identify further steps to improve and facilitate compliance, increase and harness deterrence, and invigorate the cross-government toolkit.

Anyone involved in advising on or implementing sanctions programs should take note of the content of these findings as they illustrate where the United Kingdom’s sanctions implementation agencies will be focusing over the next few years.

The UK government has committed to implementing these below steps in the financial year 2025–2026:

Compliance

1. Targeted Guidance and Enhanced Outreach: Additional guidance will be published for sectors less familiar with sanctions.
2. Clearer and More Accessible Guidance: Guidance will be better organised, modern and searchable, with read across clearly signposted. There will be comprehensive updates to sanctions pages and statutory guidance on GOV.UK.
3. Single Sanctions List: A single sanctions list incorporating the UK Sanctions List and the Consolidated List of Financial Sanctions Targets will be created to assist with screening for designated persons, especially those targeted with non-financial designation.
4. Ownership and Control: Further guidance will be published on ownership and control obligations.

Deterrence

1. Publication of Enforcement Information: Case studies will be published on a range of sanctions breaches to highlight enforcement actions.
2. Sanctions Enforcement Strategy: A government-wide sanctions enforcement strategy will be published to detail the range of enforcement outcomes available.
3. Penalty Settlement System: The UK government has committed to developing an early civil settlement scheme for breaches of financial sanctions.
4. Fast-Track Penalties: An accelerated civil penalty process for certain financial sanctions breaches will be developed to allow more resources and time to be given to the most complex, serious and deliberate of breaches

Toolkit

1. Making It Easier to Report Suspected Breaches: Reporting requirements will become clearer and easier with the potential for a single reporting point for suspected breaches.
2. Whistle-Blower Protections: The current protection for whistle-blowers will be extended to encompass not only a worker making a disclosure to an employer, a legal advisor or a “prescribed person,” but also to prescribe relevant government departments in relation to financial, transport and certain trade sanctions.
3. Future Commitments: The UK government has committed to exploring a number of other areas to go further and deeper to improve sanctions enforcement and implementation depending on resourcing and emerging priorities.

Conclusion

These efforts aim to ensure the United Kingdom’s sanctions are robust, clear and effectively support foreign policy and national security goals.

For further information, please see our corresponding alert.