Sanctions and Anti-Money Laundering Act (UK, 2018)

The Sanctions and Anti-Money Laundering Act 2018 is the United Kingdom's principal framework authority for autonomous sanctions regulations and specified anti-money-laundering measures. The detailed prohibitions sit in regulations made under the Act, not in the framework statute alone.

Regulation-making authority

The Act authorises ministers to make sanctions regulations for stated purposes, including compliance with UN obligations, international peace and security, foreign-policy objectives and prevention of terrorism. Regulations can provide for designations, asset freezes, trade and transport restrictions, immigration consequences, licensing, information and enforcement.

The exact measure depends on the regime regulation. Russia (Sanctions) (EU Exit) Regulations (UK, 2019) is one example. A framework power does not mean every available prohibition applies in every regime.

Designation decisions must use the applicable statutory and regulatory criteria. Review, revocation and court challenge are distinct processes. Kadi v Council and Commission (ECJ, 2008) concerns EU constitutional review and is relevant context, but it does not supply the current UK procedure.

Administrative division

The Foreign, Commonwealth and Development Office leads policy and designations. The Office of Financial Sanctions Implementation (OFSI) handles financial implementation, licensing and civil enforcement. The Office of Trade Sanctions Implementation (OTSI) handles specified trade-sanctions functions. The Export Control Joint Unit administers strategic export controls.

Those roles can overlap around one transaction without becoming interchangeable. Criminal investigation, prosecution and judicial review involve additional bodies. Editors should identify the competent authority rather than attribute all sanctions action to Treasury or OFSI.

Current assessment

The Act remained in force and amended as at 30 July 2026. Current regulations, guidance, lists and licences must be checked on publication day. A count of regimes requires a stated method because country, thematic and UN regimes can be grouped differently.

Strategically, SAMLA preserves domestic capacity to create and adapt restrictive measures. Enactment alone does not show implementation quality, target compliance or coalition effect. Assessment should separate the legal power, regulation made, designation, licence, enforcement event and observed outcome.

Anti-money-laundering provisions under the Act also should not be treated as sanctions designations. Both can affect financial institutions, but their legal tests, regulated persons and consequences differ.

Drafting and review controls

Regulations made under the Act should identify their statutory purpose, territorial scope, prohibitions, exceptions and enforcement provisions. Later amendments can alter one schedule or definition without changing the whole regime. Consolidated text should be checked against commencement and transitional provisions.

Designation is also only one route. Some trade restrictions apply by goods, destination or service without requiring a named person. Conversely, a designated person may be subject to financial consequences while a proposed trade does not fall within a specified product restriction.

Review can occur through ministerial reconsideration and court challenge under the applicable provisions. Editors should state whether a decision is final, under review or revoked. A successful challenge to one designation does not invalidate the framework statute.

For comparison with EU or other national systems, functional similarity should not be treated as legal identity. Jurisdiction, ownership rules, licensing grounds and enforcement powers may differ even when governments coordinate policy.

Sources

1. UK legislation, current Sanctions and Anti-Money Laundering Act 2018 (accessed 30 July 2026).
2. UK Government, sanctions guidance collection (accessed 30 July 2026).
3. UK Government, Office of Financial Sanctions Implementation (accessed 30 July 2026).
4. UK Government, applying to OTSI for a sanctioned-trade licence (accessed 30 July 2026).