As a key tool for national security, the centrality of sanctions to the UK's foreign policy, national security and the rules-based international system cannot be overstated. Since most UK economic and financial sanctions are agreed and implemented by the EU, Brexit will bring about a seismic shift in how the Government approaches this essential policy area.
Unclear, muddled position on key issues
However, three years after the Referendum, MPs were deeply concerned that little high-level thought appears to have gone into considering the future of UK sanctions policy. Written and oral evidence to the Committee revealed an unclear, muddled position on key issues such as UK's power to adopt and implement Magnitsky sanctions while still an EU member and during any potential post-Brexit implementation period. Nor was it evident that the FCO had given any strategic thought to where the UK may want to continue aligning with the EU and other allies, and where the UK might want to diverge by setting sanctions of its own.
The FCO should step up to its responsibility
The report also makes clear that Government departments are not joined up enough in their approach to sanctions. This is particularly disheartening following the Committee's 2018 Moscow's Gold report, and the importance of London to the international financial system. Rather than saying that financial crime is 'not quite' the Foreign Office's 'patch,' the FCO should step up to its responsibility to crack down on the laundering of dirty money and keep the UK and its allies safe.
The Committee believes the time is right for a major review of the Government's approach to sanctions at every stage: overall strategic goals, policy planning and formation, implementation and enforcement. Government must set out a clear-eyed position on sanctions or risk sending all the wrong signals.
Robust, effective and coherent sanctions policy essential
Chair of the Committee, Tom Tugendhat MP said:
"As we prepare to leave the EU, the UK must have the best tools at our disposal. A robust, effective and coherent sanctions policy is essential.
We hoped to find that the FCO was well-prepared in this area, with a strong sense of its goals and strategic priorities. Given how serious this issue is, we really wanted to find evidence of strong partnerships across Government departments. We are deeply concerned that the evidence tells a different story. The UK has been a champion of the rules-based international system, leading the way, but the Government’s lack of clarity risks our reputation and our national security.
The UK cannot afford the risk that its sanctions policy is dictated by others. We must be ready to take responsibility for designing, implementing and enforcing our own sanctions. We urge the Government to act on the recommendations we’ve set out in the report and seize the opportunity to become a global leader in sanctions policy."
In particular, the Report:
Calls on the National Security Council (NSC)to begin an urgent review of UK sanctions policy with internal and external stakeholders, to report to Parliament by end of 2019.
- Urges Government to appoint a Senior Responsible Officer for sanctions policy across Government departments, who will be personally accountable to the NSC.
- Calls on the FCO to publish set out its position on Magnitsky sanctions before the end of June 2019.
- Supports the Treasury Select Committee’s recent call on Government to complete and publish a review of the Office of Financial Sanctions Implementation before the end of 2019.
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