- Considers it “constitutionally inappropriate” for Ministers to have such broad delegated powers, in particular to create new forms of sanctions, and says there must be sufficient safeguards and adequate parliamentary scrutiny to make those powers “constitutionally acceptable”.
- Recommends that the requirement for designation decisions to be limited by the concept of “proportionality” should appear on the face of the Bill, that EU law remedies for those subject to UN sanctions should be retained, that reviews of designations should take place more frequently than every 3 years, and that those designated are given rights of defence.
- Invites the House of Lords to consider whether the power to designate by description as opposed to name, and by connection with certain countries, are appropriate, too broad and whether they comply with legal certainty.
- Expresses “deep concern” that the Bill permits criminal offences to be created by regulation.
- Asks whether the consent of the devolved legislatures should be required when regulations are made amending or repealing legislation that they enacted.
The Explanatory Notes to the Bill have also been published – link here.