Global Anti-Corruption Sanctions Regime 2021
On 26 April 2021, the Global Anti-Corruption (GAC) sanctions regime was established via The Global Anti-Corruption Sanctions Regulations 2021. The primary legislation underpinning the Regulations is the Sanctions and Anti-Money Laundering Act 2018.
The GAC sanctions regime allows the UK government to impose sanctions in response to serious corruption around the world. The regime is not intended to target individual countries, but individuals or organisations involved in serious corruption.
The measures which can be imposed under the GAC sanctions regime are travel bans and asset freezes.
In addition, as required by Section 43 of the Sanctions and Anti-Money Laundering Act 2018, HM Treasury has published guidance by the Foreign, Commonwealth & Development Office and the Office of Financial Sanctions Implementation to assist in the implementation of, and compliance with, the Regulations. The guidance specifically covers the prohibitions and requirements imposed by the Regulations, as well as best practice for complying with the prohibitions and requirements, the enforcement of them, and circumstances where they do not apply.
HM Treasury has also published an information note for non-government organisations.
Sanctions under the regime were also announced on 26 April 2021. The UK imposed sanctions on individuals who have been involved in serious corruption from 6 particular countries: on 14 individuals involved in the $230 million tax fraud in Russia, perpetrated by an organised crime group, and uncovered by Sergei Magnitsky; on Ajay, Atul and Rajesh Gupta, and their associate Salim Essa, for their roles in serious corruption, those individuals were at the heart of a persistent pattern of corruption in South Africa which caused significant damage to its economy and directly harmed the South African people; three individuals involved in serious corruption in Honduras, Nicaragua and Guatemala – including facilitating bribes to support a drug trafficking cartel; finally, on the Sudanese businessman Ashraf Seed Ahmed Hussein Ali, known also as Al Cardinal, for the misappropriation of significant amounts of state assets in one of the very poorest countries in the world.
The full list of designations under regulations made under the Sanctions and Anti-Money Laundering Act 2018 can be found on the UK sanctions list on GOV.UK.
Foreign Secretary’s statement to Parliament, April 2021