Coordinating Sanctions After Brexit: Considerations for the Future of UK Sanctions Policy

Ahead of Brexit day, the UK government outlined an ambitious vision of the country’s future sanctions policy and its ability to design financial measures to target actors abroad. One example is the use of sanctions to address human rights abuses. In September 2019, Foreign Secretary Dominic Raab stated that as part of the UK’s role as a ‘good global citizen’, it would use its sanctions powers against ‘those who targeted journalists, whistle-blowers and human rights campaigners’. In January 2020, it was reported that the UK is seeking to work with the US and Canada to designate a list of people involved in human rights violations whose UK assets will be frozen. 

The first paper in this series on the future of UK sanctions policy after Brexit set out recommendations for how the UK’s unilateral sanctions should be designed and implemented in order to ensure legitimacy and have maximum effect. While the UK appears keen to actively use economic and financial sanctions as part of its foreign policy toolkit, it should be acknowledged that future UK unilateral sanctions regimes will not operate in isolation and will undoubtedly have more impact and legitimacy the more universally they are implemented. If a broad coalition of countries imposes sanctions against the same target, the resulting isolation of the target from those markets and related activities will deliver the greatest possible economic pressure, at least in theory. A united approach will also ensure that the target has fewer opportunities for evasion. The consideration of sanctions coordination should be an important – and urgent – priority for the UK government as it considers its future independent sanctions policy. 

During its second meeting held on 8 October in London, RUSI’s Task Force on the Future of UK Sanctions Policy (the Task Force) therefore explored the theme of ‘sanctions coordination’. The members discussed the benefits and challenges of the UK coordinating new sanctions initiatives with allies, as well as the impact UK sanctions might carry by themselves, should coordination not be possible or desired by the UK or the partners with which it is seeking coordination. 

The Task Force considered coordination where the UK has a leading role in designing the sanctions regime. This includes entirely UK-initiated sanctions initiatives, or where the UK is working closely with others from the outset to jointly put sanctions in place. Therefore, any decision by the UK to join a sanctions regime originally designed and already implemented by others is outside the scope of this paper. In these cases, such decisions are likely to boil down to a question of the foreign policy objectives of the government of the day, alongside considerations of the economic costs to the UK of joining a sanctions action and whether those sanctions comply with UK legal requirements.