All bark and no bite?: Taking stock of the UK’s enforcement of sanctions

Russia’s full-scale invasion of Ukraine in February 2022 sparked a radical shift in the UK’s use of sanctions, as the UK scaled up its ambition for this key tool of economic statecraft to deter Kremlin aggression. To its credit, the UK acted swiftly to introduce reforms that enabled it to impose faster, broader and tougher sanctions on Russia.

Yet two years on, questions are being asked about the effectiveness of these measures and whether the UK is doing enough to tackle those who bypass or breach the rules. This report takes stock of early efforts to enforce sanctions and points to the priorities that the new government should take forward if it is serious about leveraging sanctions effectively to tackle kleptocracy and dirty money.

Weak enforcement has long been the Achilles’ heel of the UK’s fight against economic crime, and the early signs suggest that sanctions are no exception. With zero fines for breaches of financial sanctions imposed since 2022, zero convictions for sanctions evasion since 2012, and zero assets permanently seized through civil or criminal action, the UK’s flatline figures call for closer scrutiny of the challenges facing enforcement.

The main barriers to the effective enforcement of sanctions do not lie in the law. On the contrary, the powers available to UK enforcement authorities are stronger and the legal toolkit more versatile than many of our closest allies. But effective enforcement is not just about giving sanctions teeth on the statute books – there also needs to be a readiness to bite with these powers in practice.

This takes political will to drive forward a clear and ambitious enforcement strategy, sustained resourcing to recruit and retain top talent on the sanctions beat, and strong structures and incentives for proactively gathering and sharing intelligence across the entire enforcement landscape. Even the strongest rhetoric on sanctions cannot patch over systemic weaknesses in enforcement strategy, capabilities and coordination.

After years of complacency in the UK about the dangers of kleptocracy and dirty money, it is vital that the new government shifts gear on enforcement as a priority for unlocking the power of sanctions.