On 26 April 2021, the UK government announced a number of designations under its new global anti-corruption sanctions regime, which is designed to stop “those involved in serious corruption from entering and channelling money through the UK” (see press release).

Under the Global Anti-Corruption Sanctions Regulations 2021 (SI 2021 No. 488) the UK government has the power to subject individuals suspected of being involved in serious corruption to an asset freeze and travel ban. The UK government has designated “22 individuals involved in notorious corruption cases in Russia, South Africa, South Sudan and throughout Latin America”; the full list can be found in OFSI’s Notice. The reasons for the designations include suspected tax fraud, bribery, misappropriation of property and facilitation of serious corruption.

When considering whether to designate additional individuals in the future, the UK government’s policy paper sets out a list of relevant considerations:

  1. the UK government’s anti-corruption policies;
  2. the scale, nature and impact of the serious corruption, including the value, sophisticated and/or systemic nature and involvement of actors outside the relevant country;
  3. the status, connections and activities of the relevant person, in particular whether designation of that individual would have an impact on preventing or combating serious corruption;
  4. any collective international action;
  5. interaction with law enforcement activities, particularly where the relevant jurisdiction’s law enforcement authorities have been unable or unwilling to the relevant person to account; and
  6. the risk of reprisals to journalists, civil society organisations, human rights defenders or whistle blowers.

The new anti-corruption sanctions regime builds upon the UK’s Global Human Rights sanctions regime which imposes asset freezes and travel bans on individuals suspected of being involved in human rights violations. United States government has welcomed the new UK regime, which it notes “gives the United Kingdom an authority similar to the United States’ Global Magnitsky program and Canada’s Justice for Victims of Corrupt Foreign Officials Act” (see press release).

 Many thanks to Jack Fowles, trainee, for his assistance in putting together this post.