On May 15, 2025, the UK Government released the findings of its cross-government review on sanctions implementation and enforcement. This review was initiated in October 2024 and spearheaded by the Foreign, Commonwealth and Development Office (FCDO) in conjunction with various sanctions departments and agencies. The recommendations aim to facilitate compliance with UK sanctions, enhance deterrence against violations, and strengthen the cross-government toolkit for enforcing sanctions.
The report outlines four government actions to aid compliance by UK nationals and companies within the UK. These include creating additional guidance for sectors less familiar with sanctions compliance, updating sanction pages on GOV.UK for clarity, consolidating sanction lists into a single list for all UK designations, and delivering measures to clarify ownership and control.
The review suggests drawing inspiration from initiatives like the Joint Money Laundering Intelligence Taskforce (JMLIT) or establishing a public-private partnership similar to it. Another suggestion is reactivating a compliance hotline to address queries about various sanctions regimes.
To increase deterrence, the review recommends publishing enforcement actions regularly as “teachable moments,” developing an early civil settlement scheme for breaches of financial sanctions, and creating an accelerated civil penalty process. However, OFSI’s data shows limited enforcement activity since January 2022.
The review also suggests invigorating the cross-government toolkit by exploring ways to clarify reporting requirements and updating whistleblower protections related to financial, transport, and trade sanctions. It highlights concerns about incentivization schemes potentially leading to low-quality reports but notes evidence supporting whistleblower incentives in strengthening enforcement against financial crime.
In conclusion, while the review’s recommendations are welcomed as steps toward improving sanctions enforcement, they are considered unambitious. Suggestions include forming a public-private partnership for sanctions compliance support and increasing funding for relevant agencies.