On 5 March 2024, the Foreign, Commonwealth and Development Office published a post-legislative scrutiny memorandum on the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). The memorandum provides a summary and preliminary assessment of the provisions and implementation of the SAMLA.

SAMLA, which received Royal Assent on 23rd May 2018, was enacted to provide new legal powers on the UK’s exit from the EU which would enable the UK to:

  • Continue to implement UN sanctions regimes.
  • Use sanctions to meet national security and foreign policy objectives.
  • Keep anti-money laundering and counter-terrorist financing measures up to date.
  • Continue to align with international anti-money laundering standards.

A range of additional specific sanctions-focussed objectives were also implemented by the Government during the development and passage of SAMLA.

The memorandum assesses SAMLA in relation to:

  • Its power to make sanctions regulations.
  • Its review by the appropriate Minister, and other reviews.
  • Its temporary powers in relation to EU sanctions lists.
  • Court reviews.  

The memorandum also has a case study which explores Russia sanctions.