Countries’ sanctions regimes are always closely related to politics and foreign policy. Hence, international sanctions will be one of the areas where U.K. will exercise its post-Brexit sovereignty to the fullest. The British government has already prepared the grounds for its autonomous sanctions regime by adopting the Sanctions and Anti-money Laundering Act in 2018.

In December 2019, the US Department of Justice (DOJ) announced a revised policy regarding voluntary self-disclosure of export control and sanctions violations by business organizations (VSD Policy). The VSD Policy, issued by DOJ's National Security Division (NSD), sets forth the criteria that DOJ, through NSD’s Counterintelligence and Export Control Section (CES) and in partnership with the US Attorneys' Offices, will now use to determine an appropriate resolution for an organization that makes a voluntary self-disclosure in export controls and/or sanctions matters.