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Brexit and beyond: UK Sanctions Policy

Professor Matthew Moran

Professor of International Security and Co-Director of the Centre for Science and Security Studies

20 January 2021

A recent report by the House of Commons Foreign Affairs Committee declared that, ‘[The] centrality of sanctions to UK foreign policy, national security and the functioning of the rules based international system cannot be overstated’. Before Brexit, the UK pursued its sanctions policy through multilateral fora, primarily the UN and the EU. The EU, in particular, offered a means of pursuing sanctions when the UN Security Council was deadlocked, or if UN sanctions were deemed insufficiently robust.

The UK had little scope to impose restrictive measures independently but did much to shape multilateral policy decisions relating to sanctions. A 2017 House of Lords report noted that the UK was ‘widely recognised as playing a leading role in developing the EU’s sanctions policy’. In this context, the UK is perhaps best categorised as a sanctions entrepreneur, drawing on decades of expertise and experience to drive many of the bloc’s sanctions policies and regimes. In recent years,for example, the UK played an important role in the development of EU sanctions on Russia overthe crisis in Ukraine. It also helped shape the bloc’s chemical weapons and cyber sanctions regimes.

The decision to leave the EU upended existing policy and practice and required a complete overhaul of the UK’s long-established sanctions architecture. The cornerstone of this effort was a new legislative framework — the Sanctions and Anti-Money-Laundering Act (SAMLA) — giving the UK power to impose, amend and enforce sanctions, including those agreed at the multilateral level. The legislation gives the government wide-ranging powers to impose sanctions, including, crucially, in areas that go beyond the current scope of EU sanctions, such as human rights and national security.

During transition, the UK was still bound by EU sanctions, but it did have the power to impose some new sanctions autonomously under SAMLA 2018. In July 2020, Foreign Secretary Dominic Raab did just that when he launched a new UK sanctions regime targeting human rights abusers,although it’s worth noting that the EU had begun preparatory work on its own global human rights regime by that point. Then, in September, the UK joined forces with Canada to impose further human rights-related sanctions against Alexander Lukashenko, the President of Belarus, and members of his regime in the wake of rigged elections.

Where are we now?

With the end of transition, however, EU sanctions cease to apply in the UK. The UK will continue to implement multilateral sanctions imposed by the UN, but beyond this the British Government is largely free to deploy sanctions as it sees fit. The UK is no longer bound by EU measures, but there will continue to be considerable alignment on sanctions. Indeed, the Government has committed to co-operating as closely as possible with the EU on sanctions policy after Brexit.

This makes sense. The UK and the EU share many foreign policy interests and objectives, and it is widely accepted that sanctions work best when applied by a coalition of states. In any case, the UK cannot hope to emulate the approach of the United States and go it alone. The dominance of the dollar in the international financial system, even if this is being challenged, gives Washington’s aggressive and far-reaching sanctions policies a weight that the UK simply cannot replicate.

Where are we heading?

From the rise of economic nationalism to the return of great power politics, the international rules based order that has held sway since the end of second world war is under considerable pressure.

This has implications for how states work together to use sanctions, and, more importantly, how effective restrictive measures are in supporting foreign policy. Moreover, those targeted by sanctions, such as North Korea for example, have developed increasingly sophisticated means of evading them. Part of the issue here is the challenge of ensuring meaningful implementation and enforcement. But this also reflects an evolving sanctions environment where those seeking to uphold international order must innovate and devise new ways of approaching sanctions.

As an EU member state, the UK wielded considerable influence over the sanctions policy of a bloc of 28 states with a combined GNP that is only slightly smaller than that of the United States. This particular form of influence has now ended.

The Foreign Secretary, Dominic Raab, has invested heavily in the idea of ‘Global Britain’ as a leading force for good and has indicated that sanctions will play a role in this effort. The real challenge,then, is how the UK can reposition itself as one of the principal centres of sanctions influence and decision-making alongside the US, the EU and the United Nations.

Part of the answer relates to leadership. The UK should seek to reinvent itself as a global sanctions leader that will shape international thinking and action on sanctions in a UK mould. The UK has abase of expertise and knowledge — including universities, think tanks and industry groups — that leaves it well-positioned to provide thought leadership on sanctions. Yet these pockets of expertise could benefit from greater coherence and a more connected approach that transcends disciplinary and sectoral boundaries.

The goal here should be a broad community of practice that engages with some of the big questions surrounding the use and value of sanctions. What combinations of restrictive measures will be most useful going forward? How can governments and multilateral organisations be innovative in their use of sanctions? How can the sanctions be shaped so as to achieve maximum impact while avoiding harm to civilian populations and legitimate commerce, and be proportional in their application to targets?

The UK’s withdrawal from the EU has the potential to significantly undermine the role and reputation of the UK as an international sanctions actor. This approach offers a means of mitigating the risks on this front while at the same time enhancing the environment within which UK policy making occurs at home.


Matthew Moran is a Professor of International Security and Co-Director of the Centre for Science and Security Studies, in the Department of War Studies, King's College London. 

This piece was originally published in the UK in a Changing Europe's new report Brexit and Beyond.

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Matthew Moran

Matthew Moran

Professor of International Security

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