Statement regarding the adoption of the UK Anti-Corruption Sanctions regime

Yesterday the UK Secretary of State Dominic Raab released a written statement confirming the adoption of the Global Anti-Corruption Sanctions Regulations 2021 into the UK’s arsenal of Magnitsky-style sanctions regimes.

In October 2020, the Daphne Caruana Galizia Foundation wrote to the Foreign, Commonwealth & Development Office (FCDO) encouraging the swift adoption of a sanctions mechanism targeting corruption to stand alongside the existing Global Human Rights (“GHR”) Sanctions regime. The FCDO notified us of their efforts to incorporate a corruption-focussed sanctions regime. We welcome the positive conclusion of these efforts.

The new Anti-Corruption Sanctions regime allows the UK to impose travel bans and asset freezes on those it designates as having engaged in, or enabled, serious corruption. The GHR Sanctions regime, which became operational last July, is designed to penalise the perpetrators of serious human rights violations to deter future abuses.

The Anti-Corruption Sanctions regime is an important mechanism for dismantling internationally widespread networks of corruption. In the context of preventing serious violations of human rights, its pertinence and potential is even more pronounced. As we noted in our statement following the EU’s introduction of a Magnitsky-style sanctions regime, victims of human rights violations are often so as a consequence of their roles in exposing or threatening the stability of corrupt networks.

The widened scope for corruption-based sanctions enables the UK to better align its future designations with those of other international regimes. Magnitsky-style sanctions have greater impact when they are made in a coordinated manner with other jurisdictions. This was evident when the UK, the EU, and Canada sanctionedChinese officials responsible for crimes against Uyghurs simultaneously.

After the UK’s move to introduce the Anti-Corruption Sanctions regime, we hope to see other jurisdictions - especially the EU - follow suit by expanding their existing sanctioning tools to cover serious acts of corruption.