London is leaning toward a tougher American stance on sanctions, while the EU may start easing pressure following the UK withdrawal.

Companies operating in Europe face a headache as the UK prepares to diverge from the European Union's sanctions regime, making it even more complex to avoid doing business with blacklisted people, businesses and countries.

A framework of EU restrictions against countries from Venezuela to Russia, designed to support goals such as defending human rights and fighting terrorism, is initially set to be largely mimicked by the UK following the end of the Brexit transition period, scheduled for the end of this year, the Financial Times reports.

But UK foreign secretary Dominic Raab is expected to outline a new British sanctions regime in February, targeted at individuals deemed responsible for human rights abuses. This is to be followed by the publication of a list of people whose assets in the UK are to be frozen. And compliance lawyers see signs that the UK will eventually gravitate closer to the US stance on sanctions. Meanwhile, the EU, shorn of a UK that has been the driving force behind much of the bloc’s sanctions regulations, could start to soften its approach.

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"I see the UK drifting to more of a mid-Atlantic position," says Sunny Mann, who co-leads law firm Baker McKenzie's UK compliance and investigations practice. He adds: "I can see the EU drifting below the current benchmark if the UK is not at the table pushing for tougher sanctions."

The UK is also expected to slap travel bans and asset freezes on Russians responsible for human rights abuses, similar to steps taken in the US following the 2012 “Magnitsky act” — named after a whistleblowing Russian lawyer beaten to death in a Moscow jail in 2009 after uncovering a $230m fraud by tax officials.

Currently, the UK sanctions policy is largely determined by the EU. Some of these sanctions are mandatory, arising from membership of the UN. Others, however, are set by the EU itself.