As we’ve discussed previously, in 2018, the UK enacted the Sanctions and Anti-Money Laundering Act (the Act), allowing it to impose its own post-Brexit autonomous sanctions regime. On July 6, 2020, the UK imposed its first sanctions under the Act: the Global Human Rights Sanctions Regulations 2020 (the Regulations).
Under the Regulations, the UK can impose asset freezes and travel bans on individuals and entities “responsible for or involved in a serious violation” of the following human rights:
- the right to life;
- the right not to be subjected to torture or cruel, inhuman or degrading treatment or punishment; and
- the right to be free from slavery, not to be held in servitude or required to perform forced or compulsory labour.
47 individuals and two entities have been added to the Consolidated List under the Regulations, consisting of:
- 25 Russian officials who were reportedly involved in the mistreatment and death of Sergei Magnitsky;
- 20 Saudi Arabian officials linked to the unlawful killing of Jamal Khashoggi at the Saudi Consulate in Istanbul on 2 October 2018;
- 2 high-ranking commanders of the Myanmar Armed Forces alleged to be responsible for atrocities and serious human rights violations against the Rohingya population; and
- 2 North Korean entities involved in running prison camps and serious human rights violations against the prisoners.
UK businesses will need to ensure compliance with the Regulations, including updating their policies and procedures as necessary. The government also made clear in its press release that these listings are the first wave, “with further sanctions expected in the coming months.” Companies will therefore also need to closely monitor further updates.
 Article 4(2) of the Regulations