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

The Sanctions and Anti-Money Laundering Act 2018 is the United Kingdom's framework authority for sanctions regulations and specified anti-money-laundering measures. Enacted on 23 May 2018, it remains in force as amended. The statute authorises regulations; the applicable prohibitions, exceptions and designation criteria must be identified in the particular regime.

Regulation-making authority

Section 1 allows the Secretary of State or Treasury to make regulations for UN or other international obligations, and for specified purposes including preventing terrorism, national security, international peace, foreign policy, human rights and democracy. Regulations must state their purpose. The available measures include financial, immigration, trade, aircraft, shipping and director-disqualification sanctions, together with supplementary provisions. These are powers to construct a regime, not a rule that every available measure applies to every target.

Financial powers in section 3 include asset freezing and restrictions on financial services and commercial arrangements. Section 5 and Schedule 1 authorise trade restrictions that may operate through goods, technology, services, countries or designated persons. Consequently, some trade prohibitions do not depend on a named-person designation. Russia (Sanctions) (EU Exit) Regulations (UK, 2019) illustrate a separate regime whose operative provisions must be read in their own terms.

Sections 15 to 17 provide for exceptions, licences, information duties and enforcement. A licence can authorise conduct within stated conditions without removing a designation. Section 21 permits regulation of conduct in the United Kingdom or territorial sea by any person, and conduct abroad by United Kingdom persons, subject also to the specific aircraft and shipping provisions. A general description of a UK connection cannot substitute for the applicable jurisdictional rule.

Designation and review

The standard named-person procedure under section 11 requires reasonable grounds to suspect an involved person. The urgent procedure can temporarily rely on corresponding foreign measures and a public-interest assessment, with statutory certification requirements and two possible 56-day periods. It does not dispense indefinitely with the standard threshold. Regulations define relevant involvement within their stated purpose.

Section 23 allows a designated person to request variation or revocation. A repeat request requires a significant matter not previously considered. Section 38 provides court review of specified decisions, applying judicial-review principles. Ministerial reconsideration, court review, licensing and revocation are distinct acts. A ruling about one designation must be distinguished from a ruling about the validity of a regulation or the Act itself.

Administrative division

The Foreign, Commonwealth and Development Office leads sanctions policy and most designation decisions, but Treasury leads designations under the domestic counter-terrorism regime. The Office of Financial Sanctions Implementation (OFSI) implements financial sanctions for Treasury, issues financial licences and handles civil enforcement. Criminal enforcement involves separate law-enforcement and prosecuting authorities.

The Department for Business, Innovation, Science and Trade leads trade sanctions with the FCDO, as recorded in OTSI's August 2026 annual review. The Office of Trade Sanctions Implementation (OTSI) handles civil enforcement within its remit. From 27 April 2026, its licensing remit also covers sanctioned goods and technology not subject to strategic export controls, and associated ancillary services. The Export Control Joint Unit retains licensing for goods and services also subject to strategic export controls; HMRC enforces customs-related restrictions and criminal trade-sanctions breaches. OTSI licensing guidance. The applicable measure determines the responsible authority. These functions should not all be attributed to OFSI.

Scope and limitations

Part 2, particularly section 49 and Schedule 2, separately authorises measures concerning money laundering and terrorist financing, including implementation of Financial Action Task Force (FATF) standards. An anti-money-laundering obligation is not itself a sanctions designation.

The framework and administrative division were checked on 25 October 2026. The consolidation flags unapplied effects, including a 2023 duty concerning domestic politically exposed persons and 2026 territorial extensions. These do not turn the framework into a single universal regime. This review does not certify every regime, current listing or licence. Section 43 requires guidance, but guidance does not replace operative regulations and their commencement provisions. Amendments may alter a single definition or schedule while leaving other provisions intact.

Strategically, the Act gives government capacity to adapt restrictive measures. The existence of that capacity does not establish successful implementation, target compliance or coalition effects. Assessment should separate the legal power, regulation, designation, licence, enforcement event and observed outcome, using evidence appropriate to each.

Sources

1. United Kingdom, Sanctions and Anti-Money Laundering Act 2018, c. 13, current consolidated text, sections 1, 3 to 17, 19 to 23, 38, 43 and 49, and Schedules 1 and 2. Checked 25 October 2026; the publisher flags unapplied effects, so its consolidation must be read with the affecting provisions.
2. UK Government, UK sanctions: government departments and agencies responsible for sanctions, full administrative guidance checked 25 October 2026.
3. United Kingdom, Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019, SI 2019/577, regulation 5; statutory guidance, updated 25 March 2026. Checked 25 October 2026.
4. United Kingdom, Financial Services and Markets Act 2023, section 77; Global Human Rights and International Humanitarian Law Sanctions (Overseas Territories) Order 2026, SI 2026/1089, article 3. Affecting provisions checked 25 October 2026.