The Future of UK Sanctions is About More Than Implementation and Enforcement

Recent months have seen a bumper policy harvest in the UK. From the strategic defence review to an updated national security strategy via the China audit, more than a dozen security-related reviews are underway or have been recently completed. Out of this crop, a sanctions review has been one of the least remarked upon. It deserves a closer look.

Blink and You’ll Miss it

The ‘cross-government review of sanctions implementation and enforcement’, published in May, was easy to miss. News of the review’s launch was tucked into a parliamentary answer from sanctions minister Stephen Doughty in November last year. But with no formal terms of reference published and only a vague ministerial commitment to ‘go further and deeper to improve our sanctions system’, it is perhaps no surprise that when the review’s conclusions were published six months later, there was no clamour: just a short parliamentary debate and no media coverage.

The bland and slightly misleading title adds further confusion. The occasion for starting the review may well have been a cross-party consensus that sanctions enforcement ‘was not where you would expect it to be’, as foreign secretary Lammy surmised before the Commons foreign affairs committee, but the review’s far-reaching remit goes beyond ‘implementation and enforcement’ and included ‘examining whether we have the right powers, approach, capacity and resourcing on policy’, as parliamentary questions revealed.

The Cinderella of UK Strategies

Yet despite the lack of fanfare and relative obscurity, the sanctions review under-promises and overdelivers in several ways. The first is clarity.

From a political mandate of taking ‘robust action against those seeking to evade our measures’, as indicated by minister Doughty, the review draws out two sets of complementary policies, under the headings of measures that ‘increase the cost of non-compliance’ and those that ‘improve and facilitate compliance’ (policy-speak for carrot and stick). The 10 recommendations that follow are clear, logical and concise.

The document also distinguishes between immediate recommendations to be put into practice within one year, and longer-term proposals, ‘depending on resourcing and emergent priorities’, i.e. officialese for inshallah. This shows an ability to prioritise and earnest intent.

Despite spanning four government departments and two agencies, the review was fast, taking only six months. Even more strikingly, three recommendations have been implemented just one month after publication: new sector-specific guidance has been published, a single-page introduction to all UK sanctions has been created on the government website and new secondary legislation protecting sanctions whistle-blowers is in force.

When is a Review Not a Review?

Another striking feature of the review is the lack of pretensions. To illustrate this, it is helpful to compare the 2025 iteration with its immediate predecessor, the 2024 sanctions strategy (‘Deter, Disrupt and Demonstrate – UK sanctions in a contested world: UK Sanctions Strategy’).

Published on the second anniversary of the 2022 full-scale invasion of Ukraine, that strategy was chiefly a chance to reflect on how UK sanctions practice had evolved considerably in a short time, following the ‘unprecedented scale, scope and pace’ of sanction designations in the Russia-Ukraine war. After piecemeal reforms - two Economic Crime Acts in as many years and some 36 statutory instruments amending Russia sanctions alone - the chief aim was to illustrate the changes that had already taken place, rather than point to the future.

While some government publications have the qualification of ‘strategy’ cast upon them, others deal with ends, ways and means (the constitutive elements of strategy, per Lykke’s 1989 definition) but eschew the sobriquet. This is the case with the recent 2025 sanctions ‘review’, which quietly addresses a number of unresolved strategic issues.

A Sanctions Strategy by Another Name

First, the issue of fragmented enforcement. The architecture of sanctions enforcement in the UK is so complicated as to require its own 4x5 explanatory table or an infographic. The review accepts that this state of things ‘could result in fewer reports being made or misdirected information’ and proposes a joint enforcement strategy and a single channel for reporting sanctions breaches.

A welcome admission and a step in the right direction, this falls short of proposing a ‘fusion centre’ (where experts from different bodies work together and share information) or a single sanctions agency to deal with enforcement, evasion and intelligence (as proposed by former HM Treasury policy advisor James Gillespie).

An attempt to bridge bureaucratic practices can be also discerned in the promise to publish more ‘teachable moments’ about sanctions enforcement: the proposal is a compromise between the anonymity granted by HMRC to those paying up for trade sanctions breaches through a so-called compound settlement (in other words, a fine), the name-and-shame approach to financial sanctions violations by the Office of Financial Sanctions Implementation (with selective public disclosures of wrongdoing and a published list of fines) and the paltry data on ‘150 disruptions’ enacted by the National Crime Agency (NCA).

The review also commits to ‘exploring a joint intelligence function’ and publishing a report on the way forward by April 2026. Some ambiguity remains as to what is meant by these: greater information sharing across departments (an effort ongoing since 2022); pooled investigative intelligence across the alphabet soup of existing enforcement bodies; and greater exploitation of open-source intelligence are all options. The opposition spokesperson understood them as involving ‘Five Eyes‘ and secret strategic intelligence.

The Hard Questions

Perhaps the most significant step of the sanctions review is the commitment to do away with magic thinking in sanctions policy. Framed in quiet language, the review calls for more rigorous thinking around causes and effects before adopting sanctions (‘a theory of change’) and for explicit delisting criteria (‘greater public visibility of decisions to vary or revoke sanctions due to foreign policy or behavioural changes [...] as part of the sanctions life cycle, including the lifting of measures’).

Some of the ‘core considerations‘ of the 2024 strategy are restated with added conviction and clarity, reflecting an extra year of experience in the G7+ Russia sanctions coalition:

• Maintaining unity of political intent trumps adopting identical sanctions packages (‘sanctions work best when multiple countries work together… this does not mean that we will always take identical and simultaneous action’).

• Sanctions must ‘always’ be used as part of an integrated strategy of influence or coercion including political, diplomatic and/or military elements, where sanctions ‘complement and reinforce other levers rather than act in isolation’ (a step up from the 2024 language about deploying sanctions ‘selectively’ and ‘not lightly’).

• The centrality of measurement and sanctions effectiveness, reflecting the data revolution that has been ushered in by a greater number of security cleared analysts in government: ‘we design with implementation and enforcement in mind… draw on evidence from multiple sources… assess sanctions’ effectiveness against a regime’s original objectives, changing circumstances and emerging evidence, adapting our approach and measures as needed’.

Money

Finally, the review does not completely avoid the question of means, i.e. the money needed to fund sanctions enforcement and policy work. Hidden in the text is the suggestion that sanctions enforcement and economic statecraft projects across government ‘will’ continue to ‘be funded by EDI (Economic Deterrence Initiative)’, a little-known but game-changing pot of funding introduced in 2023 to ensure a step-change in sanctions enforcement and greater preparations around economic security in a world where economic warfare becomes more prevalent.

Originally due to end this year, news of its continuation is welcome, as sanctions fines do not fund enforcement work and the economic crime levy only benefits some NCA sanctions-related work. The level of future funding remains as yet unspecified, though some solace can perhaps be found in the realisation that ‘issues like [...] sanctions enforcement are going to become increasingly important’, found in the freshly published national security strategy.

A strategy that does not call itself a strategy but deals with ends, ways and means, plans for incremental reforms, and puts forwards a timetable. What is not to like?

© Andrea Marchesetti, 2025, published by RUSI with permission of the authors.

The views expressed in this Commentary are the authors', and do not represent those of RUSI or any other institution.

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