On 12 October 2018, the Foreign and Commonwealth Office published a technical notice explaining how the UK would implement sanctions if the UK leaves the EU without a deal.

Sanctions, often known in the EU as restrictive measures, are a foreign policy and national security tool which impose immigration, trade, financial and transport restrictions.

If there is no deal, the guidance says that:

  • as international law requires, the UK will continue to implement UN sanctions after the UK leaves the EU;
  • the UK will look to carry over all EU sanctions at the time of departure, and will implement sanctions regimes through new legislation made under the Sanctions and Anti-Money Laundering Act 2018;
  • the new legislation will be put before Parliament before March 2019. Any sanctions regimes that are not addressed would continue as retained EU law under the European Union (Withdrawal) Act 2018. This means there will be no gaps in implementing existing sanctions regimes;
  • the UK's sanctions regulations will include the purposes of the sanctions regime, the criteria to be met before sanctions can be imposed on a person or group, details of sanctions, such as trade and financial sanctions, details of the exemptions that may apply and enforcement measures. Regulations would be published as normal.

After the UK leaves the EU, in addition to implementing UN sanctions, and looking to carry over existing EU sanctions, it will also have the powers to adopt other sanctions under the Sanctions Act. The UK will work with the EU and other international partners on sanctions where this is in its mutual interest. The guidance also gives details of Individuals and companies concerned with the implementation of sanctions need to do.