AML: HMRC flexes enforcement muscle to the tune of £7.8 million
Ensuring that the UK “makes a success of Brexit” was the key theme of the Queen’s Speech 2017 (21June). It included eight bills to deal with the major constitutional and legal changes required as the UK leaves the EU. (See our related blog).
One of the follow up debates on the Queen’s Speech (26 June) centred upon foreign affairs and defence. How the UK operates on a global stage post-Brexit in terms of trade and regulatory cooperation is a key question. One of the answers to this appears with the presentation of an International Sanctions Bill. The Bill is designed to support the UK’s role as a “leading player on the world stage, by establishing a new sovereign UK framework to implement international sanctions on a multilateral or unilateral basis.”
Sanctions have been frequently imposed by the EU in recent years, either on an autonomous EU basis or implementing binding Resolutions of the Security Council of the United Nations. The Government seeks to ensure that the UK continues to play a central role in negotiating global sanctions to counter threats of terrorism, conflict and the proliferation of nuclear weapons post-Brexit. Whilst the UK would no longer be within the EU regime, it is worth re-calling that the UK Government is a permanent member of the UN Security Council, independent of its current EU membership.
The Government’s “background notes” accompanying the Queen’s Speech set out how legislation in this area will “enable the UK to continue to impose, update and lift sanctions regimes both to comply with our international obligations and to pursue our foreign policy and national security objectives” post-Brexit. The UK currently implements 34 sanctions regimes, which “aim to influence a change in unacceptable behaviour, constrain activities like a country’s nuclear or chemical weapons programme, or communicate a strong message of disapproval.”
A domestic legislative framework under the Bill will allow the Government to impose sanctions to ensure compliance with obligations under international law post-Brexit. These include: asset freezes, travel bans and trade and market restrictions. Alongside these measures, provisions can be set down to ensure individuals and organisations can challenge or request a review of the sanctions imposed on them. Under the new regime the Government will exempt or license certain types of activity, such as payments for food and medicine, which would otherwise be restricted by sanctions.
It will also be able to amend regulations for anti-money laundering and counter-terrorist financing and to pass new ones after the UK’s exit from the EU. (See related blogs on Money Laundering here).
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