Anti-corruption sanctions: Key takeaways

In recent years, economic sanctions have received significant attention in connection with countries such as Russia, North Korea, and Iran. However, economic sanctions may also be deployed against individuals, including public officials, who the sanctioning state perceives as engaging in corrupt behavior.

These "anti-corruption" sanctions differ from "geographic" sanctions in that they are punitive – as noted, they focus on specific persons perceived as engaging in corrupt behavior, not the economic activity of a broader collection of persons and sectors that the sanctioning state may wish to reshape.

At the same time, anti-corruption sanctions also differ from traditional anti-corruption legislation, in that they are imposed as new laws or regulations by foreign offices – not as penalties by courts or prosecutors following breaches of pre-existing laws or regulations.

In this article, we discuss how anti-corruption sanctions are used in the United States, United Kingdom, and European Union and provide two key takeaways for identifying and mitigating risk.

What are sanctions?

Economic sanctions are restrictions on trade and financial transactions for foreign policy purposes. Sanctioning states can impose a wide range of such restrictions, from virtually total prohibitions on economic activity to more targeted caps or limits on specific types of transactions.

One of the most common types of economic sanctions is the "asset freeze" or "blocking" sanction, which broadly prohibits persons from the sanctioning state from engaging in transactions with a named target, as well as with entities that the named target "owns" (US) or "owns or controls" (UK or EU). In practice, where a target of such "asset freeze" or "blocking" sanctions is a natural (rather than a legal) person, sanctioning states often also impose travel or immigration bans.

What are anti-corruption sanctions?

Anti-corruption sanctions are sanctions where the named targets are persons that the sanctioning state considers to have engaged in corruption that is significant enough to merit restrictions on their economic or financial activity or freedom of movement. Often, the named targets are government or public officials who are deemed by the sanctioning state to have engaged in significant corruption.

The first modern anti-corruption sanctions were imposed by the US in 2012 and targeted 18 Russian officials identified as implicated in the detention and death of Russian tax lawyer Sergei Magnitsky, who died in prison after identifying a USD230 million tax fraud by the Russian state.

In 2016, the US widened the legislative basis for anti-corruption sanctions, authorizing the US to impose sanctions on (among others) any government official responsible for or complicit in "acts of significant corruption, including the expropriation of private or public assets for personal gain, corruption related to government contracts or the extraction of natural resources, bribery, or the facilitation or transfer of the proceeds of corruption to foreign jurisdictions."

What anti-corruption sanctions are imposed by the UK and the EU?

In April 2021, the UK enacted the Global Anti-Corruption Sanctions Regulations 2021 (the Regulations), which authorize the imposition of sanctions on any person who "is or has been involved in serious corruption." According to Dominic Raab, at the time Secretary of State for Foreign, Commonwealth and Development Affairs, the Regulations enabled the UK to impose sanctions on "individuals who are responsible, and should be held responsible, for graft, and the cronies who support or benefit from their corrupt actions."

Anti-corruption sanctions have since featured prominently in the UK's Anti-Corruption Strategy (Strategy), published in December 2025, in which the UK pledged to "expand the use of sanctions against corrupt actors" and, in particular, to use sanctions to "target professional enabler networks." The Strategy also highlighted the UK's "innovative use of sanctions against kleptocrats and their enablers," a "step change" in approach exemplified by a series of 2024 sanctions "who had siphoned wealth from Ukraine, Angola and Latvia for their personal gain."

As of June 2026, the UK had designated 64 individuals and one entity pursuant to the Regulations. The most recent designations were in April 2025, when 13 persons were designated from Georgia, Guatemala, and Moldova. The Moldovan persons were designated for association with Ilan Shor, who, according to Reuters, was sentenced to prison in 2017 for his involvement in the theft of USD1 billion from Moldova's banking system (and who has himself been designated since 2022). The Georgian and Guatemalan persons were designated for corruption in public office, including receipt of bribes and other improper advantages while exercising a public function.

In a point of contrast between the UK and EU regimes, proposals for a dedicated anti-corruption sanctions regime put forward in May 2023 have historically been blocked by Member States.

How can risks flowing from anti-corruption sanctions be identified and mitigated?

For firms and companies that do business in jurisdictions with higher perceived risks of corruption, the key takeaway is that legal risks flowing from anti-corruption sanctions manifest differently than legal risks flowing from either traditional anti-corruption legislation or traditional geographic sanctions.

To identify and mitigate these particular risks, compliance officers are encouraged to consider:

• Identifying commercial touchpoints to counterparties and public officials in jurisdictions with higher perceived corruption risks (for example, based on Corruption Perceptions Index scores), and conducting proportionate sanctions screening to identify and protect against transactions with current targets of applicable anti-corruption sanctions; and
  
  
• Conducting a proportionate forward-looking assessment of the risk that relevant sanctioning authorities might impose anti-corruption sanctions in the future on these counterparties or officials, particularly where such sanctions would appear likely to have a material impact on business.

To discuss how anti-corruption sanctions might affect your business, please contact Katie Palms, Lydia Rogers, or Isabel Fincham on DLA Piper’s International Trade and Government Affairs teams.