The FCDO has carried out a preliminary post-legislative assessment of SAMLA 2018. The analysis looks at the background to the legislation and sets out the powers it contains. It is divided into sections, focusing mainly on financial sanctions and money laundering, and contains a specific case study on Russian sanctions. Among the preliminary conclusions are:
- that SAMLA contains the powers the UK needed to make sanctions post-Brexit and that the powers have been well used, and meet their political objectives. The amendments made to allow urgent designations have also worked as intended;
- the ministerial framework for review is appropriate and meets the Government’s objectives;
- while the temporary powers in relation to EU sanctions lists never needed to be used, their inclusion in the law was good evidence that the UK could continue to comply with UN obligations during the Brexit transition;
- the framework for challenge of designations has been tested and work to provide the necessary robust framework; and
- the parts of SAMLA that allow for changes to the MLRs have worked well.