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Key definition
Sanctions definition

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,...

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UK financial and trade sanctions for insurers: post‑Brexit framework, OFSI/OTSI/FCA enforcement, screening and due diligence

Practice notes
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Insurers must negotiate a patchwork system of financial and trade sanctions.

Within the UK, HM Treasury leads on the financial sanctions regime, operating via the Office of Financial Sanctions Implementation (OFSI). Trade sanctions sit with the Department for Business and Trade, delivered through the export control Joint Unit (overseeing the UK’s export control system) and the Office of Trade Sanctions Implementation (OTSI), which handles civil enforcement of most trade sanctions linked to the movement of goods involving UK firms that do not cross the UK border). The Department for Transport manages shipping-related measures, while the Foreign, Commonwealth and Development Office sets the UK’s overarching sanctions policy. UK trade and financial sanctions reflect United Nations security Council decisions, alongside unilateral UK listings and measures with equivalent effect to financial sanctions, including those made under the Anti-terrorism, Crime and Security Act 2001. The overarching framework stems from the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). Specific regimes and enforcement rules are put in place through statutory instruments made under SAMLA 2018. An example...

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Daniel Martin
Daniel Martin

HFW

Daniel advises traders, shipowners, freight forwarders, insurers and brokers on a host of regulatory and compliance issues, including international trade sanctions, export controls, customs and anti-corruption legislation. He advises on all aspects of the EU and UK sanctions legislation, and he is also familiar with the application of US sanctions to non-US persons. Daniel also advises clients on disputes arising from charterparties, sale contracts, bills of lading, marine insurance and logistics operations, and he uses that experience and expertise to provide detailed, practical advice which is tailored to clients in the commodities, shipping, logistics and marine insurance sectors. As well as advice on dispute resolution, customs and regulatory compliance (including ways to engage effectively with HMRC and other regulators), he also advises on compliance procedures and controls which traders, shipowners, logistics companies, banks, insurers and brokers should adopt to minimise...

Web page updated on 22/05/2026

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