The UK as a Third Country: The Current Model of Cooperation with the European Union in the Adoption of Restrictive Measures

This Insight examines how the UK has shaped its sanctions policy from the start of the transition period until the first three months following the UK’s withdrawal from the EU. The objective of the Insight is to assess whether the UK has aligned with the EU restrictive measures based on art. 215 TFEU or has made political choices that significantly depart from those of the EU in the adoption of sanctions regimes. The following trends may be highlighted. On the one hand, the UK has shaped its sanctions policy independently of the EU. In particular, the UK enacted a global human rights sanctions regime that presents differences from that of the EU and has on several occasions been applied independently of the EU in the practice. On the other hand, the UK has incorporated most of the EU sanctions acquis and has also aligned with the restrictive measures adopted by the EU in specific cases. Despite the presence of differences in the sanctions regimes of the EU and the UK, at the moment the policy choices of the two subjects of international law are similar. However, in the future, the divergence between the sanctions regimes applicable in the EU and UK legal orders may grow, for instance with respect to the designations of the addressees of restrictive measures.