Recommendation 12

In contrast to the UK, the EU periodically reviews its individual sanctions regimes. This issue is linked to the creation of arrangements for sanctions to be lifted. In our view, the Government should consider introducing a process for periodic review of sanctions in force, which could provide a mechanism for the eventual removal of sanctions, in coordination with EU and other partners. We recommend that the Government should in the meantime consult with the EU on the design of any “off-ramp” arrangement through which sanctioned entities could be removed from the sanctions list if certain conditions are met, such as providing support for reconstruction of Ukraine.