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Sanctions meaning

What does Sanctions mean?
Sanctions are the penalties or procedural consequences a court imposes in civil litigation when a party fails to comply with procedural rules, practice directions or court orders. Common sanctions include striking out or dismissing a claim or defence, debarring a party from relying on evidence or experts, costs orders (including indemnity or wasted costs), stays, unless orders with automatic strike-out on non-compliance, and, in serious cases, contempt remedies. In England and Wales, sanctions are imposed under the Civil Procedure Rules (for example CPR r.3.1, r.3.4, r.3.5, r.32.10 and r.3.14). A party may seek relief from sanctions under CPR r.3.9, applied in accordance with Denton v TH White, considering seriousness of breach, reasons, and all the circumstances. Northern Ireland and Ireland adopt broadly similar case management powers under their own procedural codes (Rules of the Court of Judicature (NI) and Rules of the Superior Courts), with applications to extend time or set aside sanctions determined by the interests of justice, proportionality and prejudice. In Scotland, comparable powers exist under the Court of Session and Sheriff Court rules. Note that “sanction” in Scotland can also mean the court’s approval to employ counsel or experts to recover expenses.
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View the related Checklists about Sanctions

CHECKLISTS
UK financial sanctions: OFSI licence applications—practitioner checklist from pre-application to post-approval compliance

Checklist The Office of Financial Sanctions Implementation (OFSI), a part of HM Treasury, is responsible for communicating, implementing and enforcing financial sanctions in the UK. It also holds powers to grant licences that permit an activity or transaction which would otherwise be prohibited under the UK financial sanctions regime. OFSI may only issue licences connected to financial sanctions. If your application concerns a different sanction, such as trade or immigration, you must send it to the appropriate Department. See further Practice Note: Understanding the financial sanctions regime. This Checklist brings together the requirements for applying to OFSI for a financial sanctions licence, alongside recommendations to help make your application faster and easier. These are drawn from multiple sources, including the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) and regulations made under it, various OFSI guidance materials, and guidance from the Solicitors Regulation Authority (SRA). This Checklist also signposts relevant content to support compliance with these requirements and suggestions. A section is provided for you to indicate completion...

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CHECKLISTS
EU AML/CTF/CPF legal and regulatory developments timeline for financial services (2024–2026): AMLA rollout, Single Rulebook, FATF updates, virtual assets and high-risk country lists

This timeline charts activity from 1 January 2024 onwards concerning the EU-facing legal and supervisory frameworks for anti-money laundering (AML), counter-terrorist financing (CTF) and counter‑proliferation financing (CPF) within the financial services sector. It traces both milestones and roll-out of the European AML, CTF and CPF rulebook. It also tracks cross-border initiatives in AML/CTF/CPF from the Financial Action Task Force (FATF), Basel Committee on Banking Supervision (BCBS), International Association of Insurance Supervisors (IAIS), IOSCO, the Egmont Group of Financial Intelligence Units (FIUs) and the Wolfsberg Group. For added detail on the EU AML/CTF regime, consult the Financial crime and sanctions (EU Law)—overview, including Practice Notes on AMLA—direct oversight of qualifying financial services firms, the EU Sixth Money Laundering Directive (MLD6) and the EU Recast Second Wire Transfer Regulation (Recast WTR2) on cryptoasset transfers... 2026 16 March 2026 — AMLA — AMLA starts a data collection exercise to test risk assessment models. AMLA has issued the reporting package for this data collection and testing exercise...

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CHECKLISTS
CPR Part 36 (pre-6 April 2015): Defendant checklist—receiving, accepting or rejecting a Part 36 offer; costs, interest and sanctions—England and Wales [Archived]

ARCHIVED: This checklist is kept for historical reference only. It sets out Part 36 of the CPR as it applied before 6 April 2015. Where you have received a Part 36 offer on or from 6 April 2015, you should consult CPR 36 in force and our Practice Notes, Checklists and Precedents dealing with this, see: Part 36 offers—overview. If you are in receipt of a Part 36 offer that pre-dates 6 April 2015, then the version of the Part 36 rules that was in force before that date applies...

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View the related Flowcharts about Sanctions

FLOWCHARTS
Final Payment Procedure and Notices under the JCT Intermediate Building Contract 2016 (with and without Contractor’s Design) – Flowchart

This flowchart for investigating financial sanctions target matches clearly sets out the sequential actions to follow once a suspected financial sanctions target (designated person) match is found. Its purpose is to confirm that every pertinent point is addressed consistently and thoroughly throughout. Note 1 See Precedent: Financial sanctions match report form. The form is for staff to submit and record potential financial sanctions target (designated person) matches identified via the screening process...

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FLOWCHARTS
Financial sanctions screening: flowchart for investigating suspected designated person name matches, with reporting, escalation and record-keeping

Background to and scope of this flowchart On 31 October 2004—often called ‘M Day’—providers and brokers involved in regulated mortgage contracts (RMCs) came within the regulatory perimeter. Any individual or firm undertaking a regulated activity in the UK in the course of business, where no relevant exclusion or exemption applies, is required to hold authorisation under the Financial Services and Markets Act 2000 (FSMA 2000)...

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FLOWCHARTS
Interim Payments under JCT Intermediate Building Contract 2016 and 2024—Flowchart (with and without Contractor’s Design)

This Flowchart It outlines the competent authorities tasked with implementing UN and UK sanctions pursuant to the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) within the United Kingdom jurisdiction...

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NEWS
SFO to deploy covert tactics and publish guidance to revive corporate self-reporting and enforce ECCTA 'failure to prevent fraud' from September 2025, amid DPA lull and cross-border collaboration

Nick Ephgrave Nick Ephgrave acknowledged it was no secret that the SFO has witnessed a slight drop-off in the number of companies approaching the specialist anti-corruption body with suspected fraud and bribery within their organisation. To address this, the SFO intends to invest further in covert intelligence-gathering so it can better understand what is happening in corporate settings and, in turn, either pursue targets or encourage them to come forward, he told Law360 and reporters from other news outlets. Ephgrave said he wants to be more in control of the referrals received by an agency that largely depends on businesses volunteering information, with the aim of invigorating and provoking self-reporting by companies. He added that he is really seeking to drive up the number of corporates the SFO deals with, whether through self-reporting supported by revised corporate guidance, via intelligence from whistleblowers, or by relying on good old-fashioned covert policing techniques such as surveillance, the deployment of undercover officers, and the use of informants...

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NEWS
UK Employment Rights Bill: tougher enforcement, day-one statutory sick pay and agency worker reforms raise employer costs; collective consultation trigger clarified

Although ministers insist the bill is “firmly pro-business and pro-worker”, the latest changes have yielded a final version that further ramps up the financial pressures on employers under the Labour government. Sanctions for employers who breach collective redundancy procedures will be doubled, and the Central Arbitration Committee will gain the power to levy fines on businesses that obstruct union access to the workplace. Statutory sick pay will apply to every single worker from the first day of illness, yet there is no indication of a revival of the rebate scheme the government once ran for small and medium-sized businesses and firms. A reduced payment is also presently available to individuals earning below the 2024 threshold of £116.75 per week. MPs are also expected to insert a right to a fortnight of bereavement leave for parents following a miscarriage when the ERB reaches its third reading in the House of Commons next week. On 5 March 2025, Dan Pollard, a partner at Charles Russell Speechlys LLP, described the amendments as “brilliant...

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NEWS
EBA consults on EU AML/CTF RTS: AMLA supervision selection, harmonised ML/TF risk assessment, CDD evidence, and sanctions criteria; consultation closes 6 June 2025

On 6 March 2025, the European Banking Authority (EBA) published a consultation paper setting out draft Regulatory Technical Standards (RTS). These draft RTS were issued following the European Commission’s (Commission) Call for Advice. They constitute a component of the European Union’s (EU) Anti-Money Laundering and Countering the Financing of Terrorism (AML/CTF) package, which was published in the Official Journal of the European Union on 19 June 2024...

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View the related Practice Notes about Sanctions

PRACTICE NOTES
Whistleblowing under ERA 1996: qualifying and protected disclosures, detriment and dismissal protections, prescribed persons, and best-practice policies (including 2025–2026 updates: sanctions prescribed persons and sexual harassment)

This Practice Note provides an overview of the legal framework and practical context for whistleblowing under the Employment Rights Act 1996 (ERA 1996). It offers high-level guidance for organisations and supports the drafting of your whistleblowing policy and procedures. It is not a handbook for managing whistleblowing claims, which is an employment law issue. What is whistleblowing? Whistleblowing refers to a worker disclosing information about wrongdoing (ie making a disclosure), usually—though not always—arising in the workplace. For whistleblowing protections to apply, the worker must reasonably believe they are acting in the public interest and that the disclosure points to past, current, or likely future wrongdoing within one or more of these categories: criminal offences (eg fraud) failure to meet a legal obligation miscarriages of justice risks to someone’s health and safety damage to the environment from 6 April 2026, sexual harassment concealment of wrongdoing in these categories Whistleblowing legislation is contained in the ERA 1996, as...

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PRACTICE NOTES
Vietnam Merger Control: Thresholds, Control, Mandatory Filing and Suspension, Review Timelines, Foreign-to-Foreign, Joint Ventures, Penalties and Sectoral Approvals under the Law on Competition and Decree 35

NOTE—to check whether notification thresholds in Vietnam and worldwide are triggered, please consult: Where to Notify. 1. Have there been any recent developments regarding the Vietnamese merger control regime and are any updates/developments expected in the coming year? Are there any other ‘hot’ merger control issues in Vietnam? In 2020, Vietnam promulgated Decree 35 on Detailed Regulations for Implementation of the Law on Competition dated 24 March 2020 (Decree 35), which became effective on 15 May 2020. This marked a pivotal step in putting into operation the competition framework envisaged under the Law on Competition dated 12 June 2018 (Competition Law). The body designated under the Competition Law, the Vietnam Competition Committee (VCC), was established on 1 April 2023 and from that date assumed responsibility for the merger control regime. Decree 35 introduced the following clarifications to merger control: Notification thresholds, under which a transaction must be notified where: the total assets or turnover in Vietnam of...

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PRACTICE NOTES
UK pre-Bribery Act 2010 bribery and corruption: prosecuting and defending, charging choices, conspiracy, corporate liability and managing historic exposure [Archived]

ARCHIVED: This archived Practice Note offers a practical guide to running and resisting investigations and prosecutions under the UK’s former corruption framework that applied before the Bribery Act 2010 (BA 2010) commenced (the pre‑BA 2010 regime). It addresses: how to frame charges for common law bribery (ie under the relevant statutes), including charge selection for conduct straddling both regimes case law defining a public body the need for a corrupt intent the presumption of corruption and associated human rights ramifications the requirements of secrecy and corruption, and what companies can do to minimise historic exposure to prosecution This Practice Note also considers: the offence of bribery at common law the Public Bodies Corrupt Practices Act 1889 (PBCPA 1889) the Prevention of Corruption Act 1906 (PCA 1906), and the Prevention of Corruption Act 1916 (PCA 1916) For details on the operative legal provisions, ongoing liability, territorial reach, and penalties and sentencing...

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View the related Precedents about Sanctions

PRECEDENTS
Sanctions definitions, warranties and compliance undertakings for share purchase agreement (pro-seller, individual sellers, unconditional long form): clause 1 and Schedule 4 insertions

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-seller—individual sellers—unconditional—long form: 1 Definitions and interpretation Sanctioned Activity • any conduct subject to sanctions set by a Sanctioning Body; Sanctioning Body • the UK, USA, EU and any other relevant authority imposing/administering sanctions; Sanctioned Entity • any person or entity that is, or is owned/controlled (directly or indirectly, per Sanctions Laws) by, a party sanctioned or listed by a Sanctioning Body; Sanctions Laws • all applicable law on Sanctioned Activities binding any Party or this Agreement’s performance; Sanctions Policy • the Sellers’ sanctions policy in Appendix [ insert Appendix number ], as updated and notified to the Buyer; 1.2 The Sellers and the Group Companies, as at the date of this Agreement and throughout its term: are not Sanctioned Entities; have not been notified of any investigation into a Sanctioned Activity; are unaware of Business circumstances that could give rise...

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PRECEDENTS
Sanctions compliance warranties and definitions for pro-buyer conditional share purchase agreement with individual sellers (long-form)

Precedent: Share purchase agreement—pro-buyer—individual sellers—conditional—long form Add the following as new definitions into clause 1 of the above stated, named precedent document herein...

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PRECEDENTS
Sanctions compliance definitions, seller warranties, due diligence and notification undertakings for pro-buyer share purchase agreement (corporate seller, conditional, long form)

Insert the following definitions as new definitions into clause 1 of Precedent: Share purchase agreement—pro-buyer—corporate seller—conditional—long form: 1 Definitions and interpretation Sanctioned Activity: activity subject to a Sanctioning Body’s sanctions. Sanctioning Body: United Kingdom, United States of America, European Union, and any other authority administering sanctions. Sanctioned Entity: any person or entity that is, or is owned or controlled (directly or indirectly) by one that is, sanctioned or on a designated list of a Sanctioning Body; ‘owned or controlled directly or indirectly’ has the meaning in Sanctions Laws. Sanctions Laws: all law on a Sanctioned Activity binding either Party or the Agreement’s performance. Sanctions Policy: the Seller’s sanctions policy in Appendix [insert Appendix number], as updated and notified to the Buyer. is not a Sanctioned Entity; has not been notified of any Sanctioned Activity investigation; is unaware of Business circumstances likely to prompt such investigation; shall comply with Sanctions Laws and the Sanctions Policy; ...

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View the related Q&As about Sanctions

Q&As
IR35 deemed employee (tax only): employer right to work checks?

Information on right to work checks generally can be found in the following Practice Notes: Right to work checks: when and why Right to work checks: how to conduct the check Illegal workers—civil and criminal sanctions Section 15(1) of the Immigration, Asylum and Nationality Act 2006 (IANA 2006) makes it unlawful to employ an adult who is subject to immigration control where they have either: not been granted permission to enter or remain in the UK, or permission that is invalid, has expired or otherwise ceased to have effect (for example, cancelled or curtailed), or is subject to a condition barring them from taking employment For more information, see the section of Practice Note: Right to work checks: when and why entitled ‘Why’...

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Q&As
Summary dismissal appeal: bail bars witness contact—proceed/adjourn?

Unfair dismissal—conduct and procedure Where an employee pursues an unfair dismissal claim, the onus lies with the employer to demonstrate a fair reason for ending employment. Conduct is one of the potentially fair grounds, but a fair process must also be observed. Ultimately, it needs to be established that dismissal is an appropriate and fair sanction. The Acas Code of Practice on Disciplinary and Grievance Procedures imposes duties on both employers and employees to follow its provisions, with possible sanctions for non-compliance. It describes the standard of reasonable behaviour expected in most situations. For further guidance, see the following Practice Notes: Dismissing fairly for conduct reasons Reason for dismissal—conduct Reason for dismissal—general, in particular section: Potentially fair reasons Acas disciplinary and grievance code—procedural requirements Under the Acas Code of Practice, certain actions—labelled gross misconduct—are so serious in themselves, or carry such serious consequences, that they may justify dismissal without notice even for a first offence. However, a fair disciplinary...

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Q&As
Relief from sanctions for late/defective list of documents?

CPR 31.10 contains provisions for the disclosure of documents by way of a list. Obligations to disclose continue until the case is concluded. If additional documents are discovered after a list has been served, a supplementary list must be provided (CPR PD 31A, para 3.3). For broader guidance on disclosure, see Practice Notes: Disclosure under CPR 31—introduction and Disclosure—standard disclosure and the reasonable search. When issuing directions, the court will fix the deadline by which the list must be served on the other party. CPR 31.21: a party cannot rely on a document it has not disclosed unless the court grants permission. CPR 32.10 (witness statements) and CPR 35.13 (experts’ reports) are framed so that, upon default, court permission is required to adduce or rely on that evidence. This points to an application for permission, rather than an application for relief from sanctions, being the more suitable course where these kinds of breaches arise...

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