The UK Government’s Sanctions Review – A Path to Better Sanctions Implementation and Enforcement?

On 15 May 2025, the UK Government published a policy paper from its cross-government review of UK sanctions implementation and enforcement¹. The policy paper commits the UK Government to introduce various measures to improve the implementation and enforcement of the UK’s autonomous sanctions regime.

Aims of the review

The UK Government’s aims in conducting the review were to identify further steps to:

1. “improve and facilitate compliance […]
2. increase the deterrent effect of enforcement […]
3. invigorate the cross-Government toolkit“

Key future measures

Following the review, the UK Government has committed to implement a range of measures, in the current financial year 2025 to 2026, to improve sanctions implementation and enforcement, most notably including:

• Creating additional guidance and clarity for sanctions compliance and ownership and control.
• Increasing engagement with sectors less familiar with sanctions compliance.

• Regularly publishing sanctions enforcement actions and disruptions.
• Publishing a government-wide sanctions enforcement strategy.
• Developing an early civil settlement scheme and an accelerated civil penalty process for certain financial sanctions breaches.
• Exploring implementation of greater restrictions on exports with a high risk of sanctions diversion

Conclusion

The UK Government’s aims are clearly intended to ensure the UK’s sanctions regime is robust, clear, and effectively supports foreign policy and national security goals. At first blush the intended measures are a positive development. In particular, the proposed early civil settlement scheme and accelerated civil penalty process should in theory ensure matters are dealt with more efficiently and proportionately.

The publication of greater guidance, especially in relation to the complex area of ownership and control, should improve certainty in applying and complying with UK sanctions. The UK Government has already updated its website to include a collective ‘hub’ for UK sanctions, which allows operators to readily locate UK sanctions content, including introductory guidance, statutory guidance, guidance by industry sector, sanctions lists and how to report a breach².

However, how effective the cross-review and its intended measures will be will ultimately depend on how the proposed actions are implemented and enforced and the response from industry and industry advisers.

Ryan Whittaker, Trainee Solicitor, assisted in the preparation of this briefing.

Footnote

1. https://www.gov.uk/government/publications/sanctions-implementation-and-enforcement-cross-government-review-may-2025/cross-government-review-of-sanctions-implementation-and-enforcement#review-conclusions-and-actions
2. https://www.gov.uk/government/collections/uk-sanctions?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery