The UK Global Anti-Corruption Sanctions Regulations 2021

Legal basis and dates

The regulations were made on 23 April 2021, laid before Parliament at 11.00 a.m. on 26 April 2021 and came into force at noon the same day ¹. They are made under the Sanctions and Anti-Money Laundering Act 2018 ².

The instrument has eight parts. They cover general matters, designation of persons, finance, immigration, exceptions and licences, information and records, enforcement, and supplementary provisions ².

What counts as corruption

Regulation 4 says the purpose of the regulations is "to prevent and combat serious corruption" ¹. Under regulation 4(2), corruption means bribery or misappropriation of property ¹.

Bribery covers offering, promising, giving, requesting or accepting an advantage to or from a foreign public official to induce or reward improper performance of a public function ¹. Misappropriation covers a foreign public official who "improperly diverts, grants or allocates" property for the benefit of the official or another person ¹.

Who can be designated

Under regulation 6, the Secretary of State may designate a person only if the Secretary of State has reasonable grounds to suspect the person is an involved person and considers designation appropriate ¹. The decision must have regard to the purposes in regulation 4 and the likely significant effects on the person ¹.

An involved person includes someone who is or has been involved in serious corruption ¹. It extends to a person owned or controlled by, acting for, or associated with such a person ¹.

What designation does

Regulations 11 to 15 set out the finance measures. They freeze the assets of designated persons and ban making funds or economic resources available to them or for their benefit ¹. Under regulation 17, a designated person is an excluded person for the purposes of section 8B of the Immigration Act 1971 ¹.

GOV.UK lists the measures as an asset freeze, a ban on making funds or economic resources available, director disqualification and an immigration sanction, or travel ban ^3,4. The regime has no sanctions on goods or services ^3,4.

OFSI guidance says an asset freeze bars dealing with funds or economic resources owned, held or controlled by a designated person ⁷. An entity is treated as owned or controlled where a person holds, directly or indirectly, more than 50% of its shares or voting rights, among other tests ⁷. Relevant firms must tell OFSI "as soon as practicable" when they know or suspect they hold assets of a designated person ⁷.

Who has been designated

The first designations came on 26 April 2021, when the Foreign Secretary announced asset freezes and travel bans on 22 individuals ⁶. The release named cases in Russia, South Africa, South Sudan and Latin America ⁶.

For Russia, the release cited people involved in diverting $230 million of Russian state property through a tax refund scheme uncovered by Sergei Magnitsky ⁶. For South Africa, it named Ajay, Atul and Rajesh Gupta and their associate Salim Essa ⁶. For South Sudan, it named Ashraf Seed Ahmed Hussein Ali, a Sudanese businessman known as "Al Cardinal", over the misappropriation of state assets ⁶.

The GOV.UK notices page lists recent changes ⁵. Its notices of 27 February 2026, 2 June 2026 and 15 July 2026 each made one variation to an existing designation ⁵. The page gives no count of designated persons and points readers to the UK Sanctions List ⁵.

Licences and challenges

OFSI, part of HM Treasury, issues licences for frozen funds only where a specific licensing ground applies ⁷. Grounds include basic needs and reasonable legal fees ⁷. Licences cannot be issued retrospectively ⁷. Part 5 of the regulations and Schedule 2 set out the exceptions, licences and Treasury licence purposes ².

Under section 23 of the 2018 Act, a designated person may at any time ask the Minister to vary or revoke the designation ⁸. A further request on the same designation is allowed only if it raises a significant matter not considered before ⁸.