• International Lawyers Project

Report on the UK’s Anti-Corruption Regime finds no new sanctions since July 2021. Why?

Updated: Jul 1

On 2nd May 2022, the UK Anti Corruption Coalition (UKACC) and REDRESS published a detailed analysis of the UK’s Global Anti-Corruption Sanctions. Introduced in April 2021, the UK’s Global Anti-Corruption Sanctions Regulations (“GACS”) have provided the UK Government with an important new tool for tackling the most egregious corrupt practices committed around the world.


The GACS regime allows the Foreign Secretary to sanction individuals and entities for their involvement in bribery or misappropriation of state assets. They are commonly referred to as a type of “Magnitsky” sanctions.


The report makes a number of interesting findings. For example, the US announced a tranche of sanctions targeting 68 individuals and entities for anti-corruption sanctions in the week leading up to the Summit for Democracy in December 2021. However, in the UK no new designations have been made under GACS since July 2021. The report also finds that the UK has currently sanctioned less than 10% of individuals designated for corruption under the US’s Global Magnitsky sanctions regime.


The Office of Financial Sanctions Implementation (OFSI), helps to ensure that financial sanctions are properly understood, implemented and enforced in the United Kingdom. In the year to March 2020, the total value of sanctions breaches amounted to £928,000,000. However, between 2018/19 to the present, the OFSI has only issued 7 monetary penalties with a total value of £20,681,000 on 6 entities (none of which were issued in relation to the GACS regime).



Of the 27 anti-corruption sanctions imposed in the first year of the GACS regime, over half relate to corruption occurring in Russia.


Overall, the report finds the effectiveness of sanctions has been undermined by:

  • a lack of anti-corruption designations;

  • the absence of a strategic approach to dismantling corrupt networks, their leadership, and enablers;

  • insufficient coordination and information sharing with other key sanctioning jurisdictions, including the US; and

  • limitations in implementation and enforcement including a severe lack of funding.

As part of a two year project focused on UK anti-corruption sanctions enforcement, ILP is working with partners in the UK Anti-Corruption Coalition and REDRESS to improve the implementation and effectiveness of the UK’s Global Anti-Corruption Sanctions regime. We specifically work on: capacity building for stakeholders and supporting the compilation and submission of anti-corruption dossiers to government intelligence officials, and guiding partners through the process from evidence-gathering to submission to the government.


Please see here for the full report, or see below to download it in PDF format.



UKACC Global Anti-Corruption Sanctions Regime Report
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Download • 557KB