The regulations will enable the UK government to impose sanctions in response to serious corruption around the world.

By Charles Claypoole, Amaryllis Bernitsa, and Robert Price

On 26 April 2021, the United Kingdom implemented the Global Anti-Corruption Sanctions Regulations 2021 (the Regulations). The legislation sets out a new Global Anti-Corruption Sanctions Regime to combat serious corruption, pursuant to the Sanctions and Anti-Money Laundering Act 2018 (SAMLA).

The Regulations allow the UK government to designate as sanctions targets (i.e., the targets of asset-freeze sanctions and travel restrictions) persons who are or who have been involved in “serious corruption” around the world, defined as (i) “bribery” or (ii) “misappropriation of property”. These terms are defined broadly as follows:

  • Bribery includes both providing a financial or other advantage to a foreign public official and a foreign public official receiving a financial or other advantage.
  • Misappropriation of property includes if a foreign public official improperly diverts or allocates property (include anything of value, including contracts or licenses or concessions) entrusted to them in their official role (whether the property is intended to benefit them or a third person).