The Sanctions and Anti-Money-Laundering Act 2018 (Commencement No. 1) Regulations 2018 have activated the bulk of the UK's new sanctions law, whose purpose is largely to permit the Government to impose non-terrorist sanctions after Brexit. Dame Margaret Hodge's amendment to the Act, however, is still awaiting activation.

Before the Act, the UK's sanctions regime dealt with terrorist finance only, with the UK leaving the issuance of other sanctions up to the European Union. The Act gained Royal Assent in May and has come into force in stages.

The new regulations activate sections 1 to 31. Section 1 allows "an appropriate minister" to make sanctions regulations if he "considers that it is appropriate" do so, for practically any reason he thinks fit. Sections 2-31 cover financial sanctions, trade sanctions, aircraft and shipping, designated persons, exceptions and licences, enforcement (section 17, which allows the minister to create new criminal offences if he likes), extra-territorial application, people's right to ask for a designation to be varied or revoked, and various reviews.

Section 21 involves the extra-territorial application of sanctions. It allows the minister to impose prohibitions or requirements under section 1 in relation to conduct in the UK or, if he chooses, conduct elsewhere (but only if the conduct is by a British person).

Sections 33 to 48 are also now in force. They cover the procedure for requests to, and reviews by, the appropriate minister, temporary powers in relation to EU sanctions lists, court reviews of decisions, protection for acts done for purposes of compliance (section 44, exempting people from civil liability if they have a reasonable belief that they have been acting (or failing to act) in compliance with section 1 or directions given by virtue of section 6 or 7), the revocation and amendment of regulations under section 1 (which, once again, allow the minister wide latitude), and the Home Secretary's power to make provision relating to certain appeals.

Sections 57 and 58, also activated, deal with duties to lay certain reports before Parliament and retained EU rights. Section 59(4) has come into force as far as it relates to the provisions coming into force in accordance with paragraph (f) of the regulation, as has Schedule 1 and paragraphs 1 to 7, and sub-paragraphs (1) to (3) of paragraph 8, of Schedule 3.

Still to be activated are ss49 and 51. Section 49 will allow the minister to issue regulations to make provision not only for the purposes of facilitating the investigation and prevention of money laundering and terrorist finance but also in favour of the implementation of standards published by the Financial Action Task Force. Section 51 is Dame Margaret Hodge's addition to the Act, covering public registers of beneficial ownership of companies registered in British Overseas Territories. It stipulates that the Secretary of State (Home Secretary) must, no later than 31 December 2020, prepare a draft Order in Council requiring the government of any British Overseas Territory that has not introduced a publicly accessible register of the beneficial ownership of companies within its jurisdiction to do so.

Terrorist financing constitutes fund-raising (banned by s15 Terrorism Act 2000), use and possession (s16), funding arrangements (s17), terrorist money laundering (s18) and jurisdictional issues (s63).