SAMLA and the New UK Sanctions Regime
SAMLA, the Sanctions and Anti-Money Laundering Act of 2018, represents the United Kingdom’s establishment of an independent sanctions policy in preparation for Brexit at the end of 2020. The legislation’s sanctions provisions are now in force and the UK Foreign Office has already designated several sanctioned parties. While these initially sanctioned parties have been carefully limited to those who have participated in unambiguous and high-level violations of human rights, the new regime shows the potential to become more expansive both in terms of the scope of targeted persons and the possible secondary effects for businesses around the world. PSA’s Michael Olver spoke with Adam Wolstenholme of Simmons and Simmons about the impact of these sanctions on the global compliance environment. Adam provides insights into how SAMLA may fit into Whitehall’s newly independent approach to regulating UK-connected transactions and highlights some potentially unanticipated risks for businesses arising from the new regime.