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The UK’s new corruption sanctions regime – Can it help end the UK’s role as a global money laundering centre and what role will journalists play?

Article by Dr Susan Hawley

March 10, 2021

The UK’s new corruption sanctions regime – Can it help end the UK’s role as a global money laundering centre and what role will journalists play?

This spring, the UK’s Foreign Secretary is set to announce a new stand-alone corruption sanctions regime which will give the Government power to impose visa bans and asset freezes on corrupt officials and their related entities.[1]


This regime will complement the Global Human Rights (Magnitsky) Sanctions regime introduced last summer, which currently lists 68 individuals. These range from those implicated in the murder of Sergei Magnitsky, a lawyer and tax advisor who exposed corruption in Russia, and the murder of Saudi Arabian journalist Jamal Khashoggi, to the former President of The Gambia, Yahya Jammeh and his wife, and the current President of Belarus. At the same time, the UK has rolled over 27 ‘geographic’ or country specific regimes, some of them introduced on human rights’ grounds, from the European Union sanctions regime.[2] These allow it to impose sanctions on individuals and entities in countries including Myanmar, Zimbabwe, Sudan, Lebanon, Democratic Republic of Congo, Syria, Guinea, and Venezuela among others.[3]


The new corruption sanctions regime will bring the UK more in line with its US and Canadian counterpart ‘Magnitsky’ regimes, which both include corruption as a grounds for imposing visa bans and asset freezes. It will also put pressure on the EU whose new global human rights sanctions regime introduced in December 2020 does not.[4]


Major opportunity, real challenges

The introduction of corruption as a grounds for sanctions in the UK is a significant opportunity in the fight against kleptocracy and dirty money globally for various reasons:

  •     The UK has long been a magnet for dirty money. An effective regime could help shut corrupt actors out of the UK and deprive them of the ability to enjoy their stolen wealth;
  •     Given the challenges that face UK law enforcement, including the length of time it takes, to bring criminal and civil enforcement action against corrupt wealth in the UK, corruption sanctions could offer a swift and powerful way of sending a strong message that corrupt actors cannot act with impunity;
  •     Corruption sanctions will be “given effect” in the British Overseas Territories and Crown Dependencies.[5] How robustly this will happen remains to be seen but this could have a major impact on the access that kleptocrats have to global financial services through these jurisdictions, which have featured heavily in all major money laundering scandals;[6]
  •     The UK will be able to act in concert on corruption sanctions with the US, Canada and other allies developing similar regimes, adding to the global impact of these sanctions; and
  •     It will signal that the current UK government is seeking to maintain a global leadership role in the fight against corruption, as part of its proposed “force for good” agenda.[7]


At the same time, it is important to be realistic about how much impact the regime will have. The UK is at a vulnerable stage in economic terms as it seeks to negotiate new trade deals around the world. Realpolitik means that there is a danger that the corruption sanctions regime may be skewed towards ‘weaker partners’ or countries where the UK has little economic or political interest. At worst, it may be applied primarily against those with no connection to the UK, leaving the sanctions purely symbolic in value. Meanwhile, the expected significant cuts in the UK’s Overseas Development Assistance (ODA) budget may well reduce the UK’s standing and leverage in countries[8] where it wishes to impose sanctions, thus undermining their effectiveness.


At the same time, the UK regime has significantly more legal safeguards built in for those being sanctioned than the US regime. Given the significant amounts of money that kleptocrats have at their disposal to defend their assets and reputations and the difficulties of proving corruption, ‘designations’ to the corruption regime may be heavily contested. This could make the Government risk averse in who it chooses to put on the list.


And finally, the sanctions regime in the UK is significantly less well funded and staffed than the US regime, meaning less capacity in the civil service to process potential designations, and less law enforcement capacity to enforce violations. This could result in relatively few designations for corruption. Additionally, as law enforcement already faces serious resource constraints, which may well be further exacerbated by cuts to the Overseas Development Aid budget that funds international corruption work, this could result sanctions being poorly enforced reducing their effectiveness.


Significance for journalists

Given their role in investigating and exposing corruption, the introduction of the regime is a major opportunity for journalists to achieve real impact with those investigations. Working in collaboration with UK and international NGOs, there is genuine opportunity here for journalists to contribute their evidence on corruption to get corrupt actors sanctioned in the UK.


Journalists will also play a key role in communicating news about sanction designations in local contexts. Coverage of when and why corruption sanctions have been imposed increases pressure for action to be taken domestically against corrupt actors and those who enable their corruption.


And finally, there may be opportunities for the sanctions regime to be used more effectively, or even extended, to protect journalists targeted for their corruption investigations and media freedom. The February 2020 report by a High Level Panel of Legal Experts on Media Freedom convened by the UK and Canadian Governments urged governments to use sanctions against those who murder or imprison journalists and restrict freedom of the media.[9] The UK’s current global human rights sanctions regime expressly prioritises media freedom, and those who commit human rights abuses against civil society, journalists and whistleblowers.[10] Those sanctioned, particularly on geographical sanctions lists, include officials and entities who have engaged in intimidation and violence against journalists, including, for example, judges in Belarus who have made politically motivated rulings against journalists, as well as those who have engaged in state propaganda.


However, there is certainly scope for the UK’s sanctions regime to go further and make clear, as the High Level Panel recommended, that arbitrary detention of journalists is an explicit ground for sanctions. And it would send a powerful message if the Foreign Secretary emphasises, when he announces the new corruption regime, that those who seek to intimidate, harass, and imprison journalists and civil society activists who expose corruption will face a serious risk of being sanctioned too.


Dr Susan Hawley is the Executive Director of Spotlight on Corruption. She is an anti-corruption specialist who has worked on anti-corruption issues in the UK for nearly two decades. She has expertise in policy and research in UK anti-corruption enforcement. Previously Susan was a founder and Policy Director of Corruption Watch UK, where she led the work on monitoring court trials, tracking UK enforcement and pushing for greater court transparency.


[1] Lisa Nandy, Topical Questions, FCDO – in House of Commons on 2nd March 2021, TheyWorkForYou, March 2021,

[2] Global Legal Monitor, European Union: Global Human Rights Sanctions Regime Enters into Force, Library of Congress, January 2021,

[3] FCDO, Collection – UK sanctions regimes, Part of Brexit,, January 2020,

[4] Council of the EU, EU adopts a global human rights sanctions regime, December 2020,

[5] FCO & FCDO, Guidance – UK sanctions, Part of Brexit,, August 2019,

[6] Transparency International UK, The Cost of Secrecy, December 2018,

[7] FCO and The Rt Hon Dominic Raab MP, Global Britain is leading the world as a force for good: article by Dominic Raab, Part of Brexit,, September 2019,

[8] Peter Geoghegan, UK government accused of ‘grotesque betrayal’ as full foreign aid cuts revealed, Open Democracy, 5th March 2021,

[9] International Bar Association, New report urges nations to use targeted sanctions to protect journalists, February 2020,

[10] FCO & FCDO, Policy Paper – Global Human Rights Sanctions: consideration of designations,, July 2020,


This article was produced as part of the Unsafe for Scrutiny project, which is kindly funded by the Justice for Journalists Foundation.

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