Don't Expect 'Identical' UK-EU Sanctions Regs After Brexit, UK Says
While the United Kingdom will continue many of the same sanctions regimes imposed by the European Union, companies should not assume the two sets of sanctions regulations will be “identical” after Brexit, the U.K.’s Office of Financial Sanctions Implementation said. In a Dec. 1 blog post, OFSI said some of its regulations have revised wording and urged businesses to review U.K. sanctions to make sure their “activities are still compliant.”
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“In many cases the process of recreating the regimes in U.K. law has necessitated clearer and more specific drafting,” OFSI said, noting some EU regimes have been “merged, separated or renamed.” Companies should also be prepared to continually screen against a constantly updating U.K. sanctions list, which will see frequent revisions because the U.K.'s “legal test for designations” will differ from the EU's. “You should be prepared for a significant number of changes to occur across multiple fields, such as aliases and other identifying information,” OFSI said.
OFSI also said the “vast majority” of existing licenses issued under EU regulations will remain valid until they expire or are revoked. The U.K. will begin issuing new specific licenses under its regulations -- which OFSI stressed contain changes from EU “licensing grounds” -- starting at 11 p.m. Dec. 31. The agency also said it will issue general licenses to “respond to unforeseeable circumstances, technical implementation issues” or when the U.K. decides a general license would benefit a sanctions regime. General license users will have to notify OFSI and keep records of their license-related activity.