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  • Writer's pictureInternational Lawyers Project

Development of the UK Global Anti-Corruption Sanctions Regime

Updated: Nov 27, 2023


ILP played an important role in the development of the United Kingdom’s April 2021 Global Anti-Corruption Sanctions regime.

This new tool targets individuals and entities involved in serious corruption, naming them publicly, banning them from travelling to the UK and freezing their assets. These new sanctions tools bring particular benefits to human rights defenders and corruption activists, who are regularly exposed to state-level arrest, legal and defamation action, or organised criminal harassment for their work.

Sanctions regimes offer a confidential and safe mechanism whereby civil society and journalists share their data directly with Western enforcement agencies, supported by ILP’s expert sanctions lawyers. Illicit financial flows lock the poorest countries in the world in a cycle of underdevelopment and conflict. By contributing to the expansion of USA and UK Global Anti-Corruption Sanctions regimes worldwide, we are reducing the spaces for kleptocrats to launder public funds that could otherwise be dedicated towards sustainable development and poverty reduction.

Ajay, Atul and Rajesh Gupta have been sanctioned for their involvement in corruption in South Africa. Sanctions give greater powers to freeze illicit assets.


ILP’s Action

ILP supported the UK Anti-Corruption Coalition and the UK Foreign Office to design this legislation, sharing technical expertise, country comparison, legal analysis, and compiling evidence dossiers on 76 possible targets leveraging our network of grassroots NGOs across the Global South. ILP is spreading the word to activists on how they can benefit from the new US and UK sanctions regimes to strengthen their role on the front line of anti-money laundering policy enforcement.

ILP hosted training workshops for 35 in-house anti-corruption lawyers representing 13 NGOs in Latin America including Argentina, Brazil, Venezuela and with more planned in 2022. We are supporting some of these with filing a sanctions submission.



As a direct result of this, the government blacklisted 27 individuals for corruption including the Vice President of Equatorial Guinea, and Ajay, Atul and Rajesh Gupta, at the centre of South Africa’s “state capture” $3 billion embezzlement scandal which contributed to the downfall of former President Jacob Zuma. Active use of this sanctions tool enhances global efforts to stop those involved in serious corruption from laundering their ill gotten gains.

ILP analyses the applicability of all enforcement tools to help our clients expose corruption including, filing formal criminal complaints with authorities in a number of jurisdictions against a UK-based Romanian businessman accused of paying millions in bribes to Senegalese politicians to secure oil concessions to help expose the role of Global North-based co-operation in bribe payments to North African officials. The BBC aired a documentary, “The $ 10 billion Energy Scandal” on Panorama Investigates.


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