New report finds UK’s enforcement of sanctions is “all bark and no bite”

The impact of the UK’s swift action to impose sanctions in the wake of Russia’s full-scale invasion of Ukraine in February 2022 is being undermined by lacklustre efforts in their enforcement, according to a new report launched today by Spotlight on Corruption.

The report – “All bark and no bite?: Taking stock of the UK’s enforcement of sanctions” – reveals that there have been 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 related to sanctions violations.

The report outlines recent reforms to boost sanctions enforcement, evaluates early enforcement efforts and suggests priorities that the new government should pursue to overcome the barriers to effective sanctions enforcement.

The report makes four key recommendations to help give sanctions enforcement real teeth: 

1. The new government should develop and publicise a clear and ambitious cross-system sanctions enforcement strategy.
2. The new government should establish a cross-departmental sanctions task force, overseen by a single minister responsible for sanctions delivery, to improve domestic coordination on sanctions enforcement.
3. The new government should launch a sanctions transparency tracker to collate and publish centralised data on sanctions.
4. The incoming chairs of parliamentary committees should collaborate on a comprehensive, cross-committee inquiry into the UK’s sanctions regime and establish parliamentary mechanisms for the routine oversight of sanctions.

Dr Helen Taylor, Senior Legal Researcher at Spotlight on Corruption and the author of the report, said: 

“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. 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.”

“All bark and no bite?” is the first in a series of reports by Spotlight looking at the current state of the UK’s enforcement of economic crime offences. Further reports in the series will be released over the summer and will cover:

• the UK’s unique model of using overseas aid to fund international anti-corruption enforcement efforts;
• current methods of reinvesting the income from fines and asset seizures into economic crime enforcement and how they can be massively scaled up; and
• the chronic problems surrounding remuneration and retention of key staff on the economic crime beat at the National Crime Agency.