On 1 February 2019, as part of the UK Government’s planning for a No Deal Brexit outcome, the UK Government published guidance relating to its sanction policy if the UK leaves the EU without a deal (available here). If the UK leaves the EU without a deal after March 2019, all EU sanctions will be carried over through new legislation, in the form of regulations, made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). The Act will provide the legal basis for the UK to impose, update and lift sanctions after leaving the EU. Those sanctions regimes that are not implemented under the Sanctions Act by March 2019, will continue as retained EU law under the EU (Withdrawal) Act 2018.

The UK Government has already published a series of technical notices setting out information to allow businesses and citizens to understand what they would need to do in a No-Deal scenario. The technical notices offer guidance for continued planning in the event of no deal. In addition, on 1 February 2019 the UK Government published guidance for various sanctions regimes if the UK leaves the EU without a deal, namely, (i) sanctions on Iran relating to human rights, (ii) sanctions on Venezuela and (iii) sanctions on Burma. Information on these pages will apply after the EU exit if the UK leaves without a deal and will be updated if a deal is agreed.

The Iran Human Rights (Sanctions) (EU Exit) Regulations 2019 (available here) are intended to ensure that certain financial, trade and immigration sanctions relating to Iran continue to operate effectively after the UK leaves the EU. The sanctions regime is aimed at encouraging the government of Iran to comply with international human rights law and respect human rights. The UK Government will publish a separate guidance on the sanctions regime on Iran related to weapons of mass destruction at a later date.

The Venezuela (Sanctions) (EU Exit) Regulations 2019 (available here) are intended to ensure that certain financial, trade and immigration sanctions relating to Venezuela continue to operate effectively after the UK leaves the EU. The sanctions regime is aimed at encouraging the government of Venezuela to respect democratic principles, to comply with international human rights law and to respect human rights.

The Burma (Sanctions) (EU Exit) Regulations 2019 (available here) are intended to ensure that certain financial, trade and immigration sanctions relating to Burma continue to operate effectively after the UK leaves the EU. The sanctions regime is aimed at encouraging the Burma security forces to comply with international human rights law and to respect human rights.