Historically, most sanctions in the UK originated from the United Nations (“UN”) or the European Union (“EU”), generally implemented via EU legislation, and governed by EU law. Following withdrawal from the EU, however, the UK is no longer bound by EU law (subject to transitory provisions).
Accordingly, a number of government departments have been working together so that ‘the UK is ready to run an autonomous UK sanctions system’.  The Sanctions & Anti-Money Laundering Act 2018 (“SAMLA”) provides the UK with a specific sanctions-making power, and associated power to introduce secondary legislation, so as to directly implement UN, EU and UK (autonomous) sanctions.
As SAMLA prescribes an ‘extremely broad’ power for the UK to run an autonomous sanctions system, including ‘extremely vague’  statutory parameters for the creation of new criminal offences, carrying a maximum of ten years’ imprisonment, should business be concerned about a substantial increase in the costs of compliance with sanctions law?
In other words, will the UK’s autonomous sanctions system mirror, maintain a broadly similar approach, or substantially differ from the EU’s autonomous sanctions system? The former means broadly similar costs of compliance, and the latter, a substantial increase.
This article therefore provides a timely overview of the current legal landscape surrounding the complex area of international sanctions, and the UK’s autonomous sanctions regime, so as to offer an informed view on whether the costs of compliance for business (and the associated penalties in default) is likely to substantially increase.
Although the aim of sanctions is usually related to the maintenance of international peace and security, sources, implementation and enforcement differ.
Sanctions are policy measures of international organisations (usually the UN and the EU) or individual states (usually the United States and the United Kingdom) with the general aim of coercing, constraining, or signalling disapproval.
In general, there are three ‘broad categories of sanctions measures’. 
First, financial sanctions, targeting the assets and economic resources of designated individuals and entities. Secondly, trade sanctions, imposing export and import restrictions. Thirdly, travel bans, prohibiting travel to, or through, the territory of the sanctioning state.
An important source of sanctions measures is the United States of America. The Office of Foreign Assets Control of the US Department of the Treasury administers a number of different sanctions programs, ‘comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals.’  The legal framework for the imposition of US economic sanctions measures is often complex, difficult, and costly to interpret, apply, and comply with.
As US sanctions measures are not fundamentally affected by Brexit or SAMLA, this article goes no further than merely noting that the US is a substantial source of sanctions measures. Two international organisations are also substantial sources of sanctions measures, however, the UN and the EU.
The UN creates sanctions measures through the UN Security Council. That is, the UN organ with primary responsibility for the maintenance of international peace and security.
Chapter VII of the UN Charter is entitled: ‘Action with respect to threats to the peace, breaches of the peace, and acts of aggression’. Within this Chapter, Article 39 requires the UN Security Council to determine the existence of any threat to the peace, breach of the peace or act of aggression. Having done so, the UN Security Council must make recommendations, or decide what measures shall be taken to maintain, or to restore international peace and security.
Article 41 of the UN Charter enables the UN Security Council to:
… take such action by air, sea, or land forces as may be necessary to maintain or restore international peace and security. Such action may include demonstrations, blockade, and other operations by air, sea, or land forces of Members of the United Nations.
UN member states must accept and carry out the decisions of the UN Security Council, by virtue of Article 25 of the UN Charter. Further, Article 103 of the UN Charter provides that, in the event of a conflict between the obligations of UN member states under the UN Charter and their obligations under any other international agreement, obligations under the former prevail. As such, the International Court of Justice has confirmed that UN Security Council resolutions are binding upon all UN members states. 
At the end of the Cold War, due to the political paralysis of the UN Security Council, there were only two UN sanctions regimes: Rhodesia, authorised by UN Security Council Resolution 253 (1968); and South Africa, authorised by UN Security Council Resolution 421 (1977). Three decades on, however, and UN sanctions regimes have increased by a factor of 15: 
To date, the [UN Security] Council has established 30 sanctions regimes in total, concerning: Southern Rhodesia, South Africa, the Former Yugoslavia (2), Haiti, Angola, Liberia (3), Eritrea/Ethiopia, Rwanda, Sierra Leone, Côte d’Ivoire, Iran, Somalia/Eritrea, ISIL (Da’esh) and Al-Qaida, Iraq (2), DRC, Sudan, Lebanon, DPRK, Libya (2), the Taliban, Guinea-Bissau, CAR, Yemen, South Sudan and Mali.
One recent example of a UN sanctions regime – in response to the conflict between the government of the Republic of South Sudan and opposition forces – is UN Security Council Resolution 2206 (2015), establishing a travel ban, assets freeze and arms embargo.
Article 21(2) of the Treaty on the European Union provides that the EU shall work towards a high degree of cooperation in all fields of international relations, so as to:
(a) safeguard its values, fundamental interests, security, independence and integrity;
(b) consolidate and support democracy, the rule of law, human rights and the principles of international law; [and]
(c) preserve peace, prevent conflicts and strengthen international security, in accordance with the purposes and principles of the United Nations Charter, with the principles of the Helsinki Final Act and with the aims of the Charter of Paris, including those relating to external borders; …
To achieve this aim, the EU has a Common Foreign and Security Policy (“CFSP”). The CFSP considers that ‘restrictive measures’ or ‘sanctions’ are an ‘essential tool’ so as: 
… to bring about a change in the policy or conduct of those targeted, with a view to promoting the objectives of the CFSP. They can target:
• governments of non-EU countries because of their policies
• entities (companies) providing the means to conduct the targeted policies
• groups or organisations such as terrorist groups
• individuals supporting the targeted policies, involved in terrorist activities etc.
Imposition & enforcement
The EU distinguishes between UN and EU sanctions measures.
UN sanctions measures are implemented by the EU on behalf of EU member states so as to ensure harmonisation. EU sanctions measures are distinguished as “autonomous” sanctions measures, in light of the fact that they are adopted and implemented unilaterally by the EU. Enforcement of UN or EU (autonomous) sanctions measures, however, is left to EU member states, who must enact their own, domestic provisions.
The EU has a history of adopting autonomous sanctions measures when the UN (Security Council) is politically paralysed. The UN Security Council comprises five permanent members – China, France, Russia, the UK and the US – and ten non-permanent members. The latter are elected by the UN General Assembly for a term of two years.
Decisions of the UN Security Council require an affirmative vote of nine members. Each member has one vote, however, all five permanent members must give their assent before a decision is crystallised in a resolution. In relation to the Syrian civil war, for example, on 19 July 2012, a draft resolution included the following recitals:
… Determining that the situation in Syria constitutes a threat to international peace and security,
Acting under Chapter VII of the Charter of the United Nations, …
The operative part of the resolution went on to record the following decisions:
… the Syrian authorities shall … (a) cease troop movements towards population centres, (b) cease all use of heavy weapons in such centres, (c) complete pullback of military concentrations in and around population centres, and to withdraw its troops and heavy weapons from population centres to their barracks or temporary deployment places to facilitate a sustained cessation of violence; [and]
… if the Syrian authorities have not fully complied with [the] above within ten days, then it shall impose immediately measures under Article 41 of the UN Charter; …
This draft resolution was vetoed by two permanent members. Six months previously, however, the EU passed Council Regulation 36/2012 prescribing restrictive measures in view of the situation in Syria. The EU adopted autonomous sanctions measures as the deadlock in the UN security Council was already obvious.
The titles of the chapters of EU Regulation 36/2012 give a flavour of the substance: export and import restrictions; restrictions on participation in infrastructure projects; restrictions on financing certain enterprises; freezing of funds and economic resources; and restrictions on financial services. This is evidence that the EU is able to adopt far-ranging sanctions of substance when the UN is politically paralysed.
The UK has justifiably been termed ‘the EU’s foremost sanctions advocate’. 
Accordingly, having left the EU, the UK is likely to continue this practice, advocating for sanctions measures in the UN, and with her EU allies, whilst also passing sanctions measures using the UK’s own, autonomous sanctions regime. The UK is likely to pass, implement and enforce autonomous sanctions measures, even where member states of the UN (and perhaps also member states of the EU) are unable, or otherwise unwilling to pass a UN Security Council resolution (or EU Council resolution): 
The UK and its international partners have also imposed and implemented sanctions in situations where the UN has chosen not to act, but where the UK has considered an international response was still necessary. Often this has involved close cooperation between the EU and the United States, with the support of others, including Canada, Australia, Switzerland and Norway. This has included creating new sanctions regimes, such as those in relation to Syria, and enhancing UN sanctions with additional autonomous measures, for example the sanctions against North Korea.
Sanctions & Anti-Money Laundering Act 2018
The historical situation – UN and EU sanctions measures were generally implemented in the UK by EU legislation, governed by EU law – ‘is set to change dramatically’. 
At the time of writing, EU sanctions will continue to apply in the UK until 11pm on 31 December 2020. After this time, in light of the fact that UN and EU sanctions measures will no longer be implemented through EU law, the explanatory notes to SAMLA rightly identify that there is a need for new powers to implement sanctions:
9. The UK’s implementation of UN and other multilateral sanctions regimes largely relies on the European Communities Act 1972. The UK has some limited domestic powers to unilaterally impose sanctions (notably in domestic counter-terrorism and export control), but these are not sufficient to implement the full range of sanctions currently in force through the UN and EU.
12. After the UK leaves the EU, the UK will be unable to continue to use the European Communities Act 1972 to implement sanctions. Therefore the UK will need a domestic framework of powers to continue to meet its international obligations to implement UN sanctions. Without this, the UK will be in breach of international law. The UK will also need new powers to implement sanctions which have not been put in place at UN level, otherwise it will be unable to co-operate with international partners, using sanctions as a foreign policy and national security tool.
Enter SAMLA: 
An Act to make provision enabling sanctions to be imposed where appropriate for the purposes of compliance with United Nations obligations or other international obligations or for the purposes of furthering the prevention of terrorism or for the purposes of national security or international peace and security or for the purposes of furthering foreign policy objectives; to make provision for the purposes of the detection, investigation and prevention of money laundering and terrorist financing and for the purposes of implementing Standards published by the Financial Action Task Force relating to combating threats to the integrity of the international financial system; and for connected purposes.
The majority of SAMLA came into force on 22 November 2018, however, no date has been set for entry into force of provisions relating to money laundering regulations.
Territorial extent is prescribed in section 63. In short, the provisions or SAMLA and secondary legislation made under it are enforceable against all persons within the UK. Sanctions regulations may also be enforced against all UK persons abroad.
Power to make sanctions regulations
Chapter 1 is entitled: ‘Power to make sanctions regulations’.
Section 1 prescribes: the power to make sanctions regulations; the three permissible purposes of making sanctions regulations; that regulations must state the purpose for which they are made; and what ‘sanctions regulations’ means.
The three purposes are as follows. First, compliance with a UN obligation. Secondly, compliance with any other international obligation. Thirdly, where the appropriate minister considers that the regulation would:
(a) further the prevention of terrorism, in the United Kingdom or elsewhere,
(b) be in the interests of national security,
(c) be in the interests of international peace and security,
(d) further a foreign policy objective of the government of the United Kingdom,
(e) promote the resolution of armed conflicts or the protection of civilians in conflict zones,
(f) provide accountability for or be a deterrent to gross violations of human rights, or otherwise promote—
(i) compliance with international human rights law, or
(ii) respect for human rights,
(g) promote compliance with international humanitarian law,
(h) contribute to multilateral efforts to prevent the spread and use of weapons and materials of mass destruction, or
(i) promote respect for democracy, the rule of law and good governance.
Section 2 prescribes three additional requirements before a minister can make regulations relating to a purpose other than compliance with a UN or other international obligation.
First, the minister must have determined that there are good reasons to pursue the purpose of the regulations. Secondly, the minister must have determined that the imposition of sanctions is a reasonable course of action for that purpose. Thirdly, the minister must lay before Parliament a report that addresses these requirements at the same time as the regulations.
Sections 3 to 8 set out the type of sanctions that may be imposed: financial; immigration; trade; aircraft; shipping; and other sanctions for the purposes of UN obligations. Section 15 enables ministers to disapply the effect of sanctions in particular circumstances, through exceptions and licences. Section 16 requires relevant information to be reported, enabling the government to collect that information, and authorises the sharing of the same with UK police officers, regulatory bodies and international partners.
Section 17 caters for enforcement in five important ways.
First, regulations may prescribe the powers and duties of any person who is to enforce the regulations. Secondly, regulations may create criminal offences, with sentences of up to ten years’ imprisonment following conviction on indictment.
Thirdly, regulations may apply (with or without modification) the provisions of the Customs and Excise Management Act 1979. This Act prescribes customs and excise control areas, controls on importation, exportation, and coastwise traffic. Fourthly, regulations may specify that investigatory powers in the Serious and Organised Crime and Police Act 2005 may be used to investigate breaches of regulations, including the power to enter and seize documents.
Fifthly, regulations may specify whether the civil monetary penalties in Part 8 of the Policing and Crime Act 2017 apply where there is a breach of a regulation. Part 8 of this Act prescribes enhanced maximum penalties including imprisonment, civil sanctions including monetary penalties for corporate bodies and unincorporated associations, and that financial and other sanctions offences are within the scope of deferred prosecution agreements and serious crime prevention orders.
In 2017, the government established a special office to ensure that financial sanctions are properly understood, implemented and enforced in the UK: 
The Office of Financial Sanctions Implementation (OFSI), which is a part of HM Treasury, enables financial sanctions to make the fullest possible contribution to the UK’s foreign policy and national security goals. It also helps to maintain the integrity of, and confidence, in the UK financial services sector.
A 34-page document published by OFSI – ‘Monetary Penalties for Breaches of Financial Sanctions: Guidance’ (May 2018) – assists business by providing five pieces of welcome guidance.
First, an explanation of the civil monetary penalties that may be used to enforce sanctions regulations. Secondly, a summary of OFSI’s compliance and enforcement approach. Thirdly, an overview of how OFSI would assess an appropriate monetary penalty. Fourthly, an overview of the process that determines the level of monetary penalty. Fifthly, how a monetary penalty will be imposed, the timescales for doing so, rights of review and appeal.
The key guidance relates to voluntary and complete disclosure in good faith, as follows:
3.30 OFSI values voluntary disclosure. Co-operation is a sign of good faith and makes enforcing the law simpler, easier, quicker and more effective. Voluntary disclosure of a breach of financial sanctions by a person who has committed a breach may be a mitigating factor when we assess the case. It may also have real effect on any subsequent decision to apply a penalty.
3.31 If multiple parties are involved in a breach, we expect voluntary disclosure from each party.
3.32 Reports regarding breaches or suspected breaches should be submitted to OFSI using the form on GOV.UK: https://www.gov.uk/guidance/suspected-breach-of-financial-sanctions-what-to-do
3.33 We expect breaches to be disclosed in a timely fashion, as soon as reasonably practicable after discovery of the breach. What this means will differ in each case. There is no conflict between timeliness and material completeness. Although it is reasonable for you to take some time to assess the nature and extent of the breach, or seek legal advice, this should not delay an effective response to the breach. In practice, it is better to contact us early to inform us of a breach or potential breach. Where full disclosure is not possible, you could make an early disclosure with partial information on the basis that you are still working out the facts and will make a further disclosure as soon as possible.
3.34 We expect disclosures to be materially complete on all relevant factors that evidence the facts of a breach of financial sanctions. We expect facts to be truthfully stated in good faith.
3.35 OFSI takes very seriously any disclosures made in bad faith and any evidence that a disclosure was not materially complete, unless this was a mistake or new facts emerge. If we discover parties have dealt with us in bad faith and if the case is not criminally prosecuted, we will normally consider imposing a monetary penalty.
3.36 To determine whether a disclosure is voluntary, we will consider the facts and timing of each disclosure individually. The mere fact that another party has disclosed first will not necessarily lead to the conclusion that later disclosure has any lesser value. However, we will not consider disclosure to be voluntary and therefore a mitigating factor if:
• we have used our information powers to require provision of information about a breach;
• the person has been prompted to disclose facts because OFSI is assessing a case; or
• the person has been prompted or required in law to disclose facts because of a separate law enforcement or regulatory investigation.
3.37 We are happy to consider marginal issues, particular circumstances, conflicts or any other issue around voluntary disclosure as part of a person’s representations.
Section 21 provides for extra-territorial application of UK sanctions regulations.
Prohibitions or requirements can be imposed on any person in the UK. This includes UK territorial waters. They can also be imposed on any UK person anywhere in the world. This includes a UK national, or a body (such as a company) incorporated or constituted in the UK.
OFSI have issued helpful guidance on who needs to comply with financial sanctions and territorial application of UN, EU and UK sanctions measures: 
Financial sanctions apply more broadly than simply to the persons subject to them. The following outlines where financial sanctions apply and who needs to comply with them.
• EU financial sanctions (including where they implement UN sanctions) apply within the territory of the EU and to all EU persons, wherever they are in the world.
• UK financial sanctions apply within the territory and territorial waters of the UK and to all UK persons, wherever they are in the world.
• All individuals and legal entities who are within or undertake activities within the UK’s territory must comply with the EU and UK financial sanctions that are in force.
• All UK nationals and UK legal entities established under UK law, including their non-UK branches, must also comply with UK financial sanctions that are in force, irrespective of where their activities take place.
• All EU nationals and legal entities established under EU law must comply with the EU financial sanctions that are in force, irrespective of where their activities take place.
Costs of compliance
Having set out a brief overview of the EU and UK autonomous sanctions systems, it is possible to analyse whether the latter is likely to mirror, maintain a broadly similar approach, or substantially differ from the former. For business, the answer to this question has the practical result of a sliding scale from broadly similar costs of compliance (and the associated penalties in default) to a substantial increase.
The most defensible position is that the UK autonomous sanctions system will maintain a broadly similar approach to the one that existed when the UK was a member of the EU. If so, business will incur broadly similar costs of compliance. This position is adopted having given appropriate weight to evidence in the form of historical precedent – in particular, UK political policy expressions – and SAMLA.
Broadly similar approach
The government’s impact assessment for SAMLA – under the heading ‘What are the policy objectives and the intended policy effects?’ – stated that: 
This legislation is not about creating new policy, but ensuring that the UK has the necessary domestic legal powers after leaving the EU to meet our international obligations and use sanctions as a national security and foreign policy tool.
For this reason, the seminal text on sanctions law concluded: 
… there is no indication that the UK will change its overall sanction policy … the UK Government has been at pains to stress that the changes to the UK sanctions framework will be formalistic, not substantive.
The impact assessment continued on the next page, however, confirming that the UK did not intend to change its overall sanctions policy, but also hinting at the relative ease of passing UK (as opposed to EU) autonomous sanctions measures:
Whilst there is no overall policy change to the way the UK will approach sanctions after we leave the EU, the proposed plans will make it easier for the Government to impose sanctions and respond quickly to events where appropriate.
As implementation of EU autonomous sanctions measures always begins with a CFSP decision, and CFSP decisions must be adopted unanimously by all 27 member states,  it is foreseeable that one state (the UK) will impose autonomous sanctions where an international organisation (the EU) is unable to. For this reason, UK autonomous sanctions measures are unlikely to completely mirror those of the EU. On occasions, the UK is likely to impose autonomous sanctions measures where members states of the EU are unable to agree.
Further, the procedure for substantial amendment to EU autonomous sanctions relating to restrictive measures requires the full implementing procedure, and so a unanimous decision of all 27 EU member states. It therefore also foreseeable that UK autonomous sanctions are amended (as a decision of only one state is necessary to do so), where EU autonomous sanctions are unable to be amended (as the decision of 27 states is necessary to do so).
EU autonomous sanctions measures implementing UN Security Council resolutions are subject to EU law, applied and interpreted by the Court of Justice of the European Union. UK autonomous sanctions implementing UN Security Council resolutions, however, are subject to UK law, applied and interpreted by UK courts.
It is therefore foreseeable that differences may emerge in the courts between UN sanctions measures implemented and interpreted in the EU and those which are implemented and interpreted in the UK. If so, this is another source of uncertainty, and corresponding increase in the costs of compliance with sanctions law for businesses operating in both the EU and the UK.
As noted above, section 16 of SAMLA provides that regulations may require reporting of prescribed matters, creation and retention of registers or records, information to be provided, and documents to be produced, inspected or copied for prescribed purposes. The explanatory notes provide the following examples:
69. In relation to financial sanctions, for example, the regulations will give the government powers to request information from a designated person on the funds or economic resources they hold, own or control or that someone else does on their behalf, and how those funds are disposed of. The government may request information on expenditure by or on behalf of the designated person. The government can use these powers when it thinks it is necessary for the purposes of monitoring compliance or detecting evasion of the regulations.
70. The regulations could also require registers or records to be maintained, and allow the government to request from any person in or resident in the UK any information that the government may reasonably require to assess compliance with licences.
Regulations will set out what information must be provided, so, only time will tell as to whether or not this reporting requirement under UK autonomous sanctions measures is more onerous than the existing requirement under EU autonomous sanctions measures.
Frustration, illegality & force majeure
Traditionally, English courts have analysed the effect of sanctions measures on commercial contracts using the concepts of frustration and illegality.  It may therefore appear that, where a commercial contractual obligation becomes difficult, if not impossible to perform, these doctrines can be invoked – so as to bring contractual obligations to an end, thereby discharging the parties from further liability thereunder – however, this will not always be possible: 
The key points to note from the limited case law on sanctions and frustration of contracts are therefore as follows:
i. Sanctions may reduce the scope of the obligations under a contract without frustrating the contract in its entirety …
ii. The courts will be very unlikely to accept that the contract has been frustrated unless the party attempting to rely on frustration can show that it would be impossible to obtain a licence …
iii. Even if the obligations under a contract are impossible to perform on account of sanctions measures, the courts may find that the contract has been suspended rather than frustrated …
In relation to point (iii) above, although it will always be unclear at what point exactly a contract which is impossible to perform due to sanctions will be frustrated, the issue will depend on the content and temporal scope of the contract itself.
Further, a force majeure clause – entitling one or both parties to cancel the contract, or excuse performance thereunder, due to the occurrence of specified events beyond the control of a party or parties – has three conditions before a party may successfully rely on it: 
He must therefore prove the occurrence of one of the events referred to in the clause and that he has been prevented, hindered or delayed (as the case may be) from performing the contract by reason of that event. He must further prove:
(i) that his non-performance was due to circumstances beyond his control; and
(ii) that there were no reasonable steps that he could have taken to avoid or mitigate the event or its consequences.
On any given facts, all three conditions are usually properly arguable. So it is often far from clear that a force majeure clause may be successfully relied upon, that is, until judgment has been handed down, after lengthy, costly litigation – and potentially successful appeal(s).
Accordingly, parties to a commercial contract cannot always rely on the concepts of frustration, illegality and force majeure to escape their contractual obligations, even when there are relevant UN or UK sanctions, implemented, applied and enforced by UK courts. In principle, this means increased uncertainty, and therefore a corresponding increase in the costs of compliance.
With UK autonomous sanctions measures, the most fundamental change is likely to be in enforcement (as opposed to implementation) of financial sanctions: 
To date, enforcement in the UK has been patchy, with only a handful of prosecutions and fines meted out for breaches of financial sanctions obligations. However, this appears likely to change with the establishment of OFSI as the new authority responsible for financial sanctions enforcement, and the entry into force of the Policing and Crime Act 2017, which contains a range of new enforcement powers.
The increased bite of the UK enforcement regime is likely to justify greater investment in compliance with sanctions law, so as to avoid identification, attribution of responsibility for non-compliance, monetary penalties, and (in the worst-case scenario) imprisonment.
The positive news is that OFSI publish and maintain lists of all: financial sanctions imposed by country, administration or terrorist group; current trade sanctions, including arms embargoes, and other restrictions; and designated persons, terrorism and terrorist financing. It is also possible to subscribe to email alerts for updates. Further guidance on UK autonomous sanctions in force (or destined to come into force from 11pm on 31 December 2020) has also been published and is maintained, including trade restrictions that don’t fall under SAMLA, and who is subject to financial sanctions. 
In any event, existing UK case law provides evidence that parties to commercial contracts should be cautious before placing reliance on the concepts of frustration, illegality, or force majeure where contractual performance is difficult (or even impossible) in light of UK autonomous sanctions measures.
11 March 2020
 Office of Financial Sanctions Implementation, ‘Annual Review: April 2018 to March 2019’ 8.
 Richard Gordon, Michael Smyth & Tom Cornell, ‘Sanctions Law’ (Hart Publishing, Great Britain, 2019) “Sanctions Law” 60.
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 Legal Consequences for States of the Continued Presence of South Africa in Namibia (South West Africa) Notwithstanding Security Council Resolution 276 (Advisory Opinion)  ICJ Rep 16 .
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 Council of the European Union, ‘Sanctions: how and when the EU adopts restrictive measures’ (10 February 2020).
 Sanctions Law 57.
 Explanatory notes to the Sanctions and Money-Laundering Act 2018 5.
 Sanctions Law 56.
 Preamble (with emphasis added).
 Office of Financial Sanctions Implementation, ‘About us’.
 Office of Financial Sanctions Implementation, ‘Financial sanctions: general guidance’ (January 2020) 8.
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 https://public.govdelivery.com/accounts/UKHMTREAS/subscriber/new [accessed 10 March 2020].
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