On 26 April 2021, UK Foreign Secretary Dominic Raab announced the country’s first sanctions under the new Global Anti-Corruption Sanctions Regulations 2021 (the Regulations). The Regulations build on the sanctions imposed under the Global Human Rights Sanctions Regulations 2020 as the UK seeks to expand its post-Brexit autonomous sanctions regime.
The sanctions under the new Regulations target 22 individuals allegedly involved in serious corruption in Russia, South Africa, South Sudan, and Latin America. Specifically, sanctions were imposed on the following:
- Fourteen Russian individuals involved in the diversion, through a fraudulent tax refund scheme, of Russian state property worth $230 million – one of the largest tax frauds in recent Russian history – uncovered by the lawyer Sergei Magnitsky;
- The Gupta brothers and their associate Salim Essa were accused of corruption in South Africa, which contributed to the downfall of the country’s former President Jacob Zuma;
- Sudanese businessman Ashraf Seed Ahmed Hussein Ali for the misappropriation of significant amounts of state assets in Sudan; and
- Three individuals accused of serious corruption in Honduras, Nicaragua, and Guatemala, including facilitating bribes to support a major drug trafficking cartel.
The Regulations have replaced the Misappropriation (Sanctions) (EU Exit) Regulations 2020 concerning the misappropriation of State funds from any country outside the UK and are based on the UN Convention against Corruption. The new Regulations allow the UK government to take a targeted approach to combatting serious corruption by imposing sanctions on individuals engaged in activities related to corruption and their enablers (that is, ‘involved persons’), preventing them from entering and channelling money through the UK.