A New Government, A Shadow Fleet, and the First Recovery of Sanctioned Assets
By Andrew Lane, REDRESS Legal Assistant
Read our latest sanctions quarterly update
Between 9 May 2024 and 4 November 2024, the UK used its targeted sanctions regimes to respond to the invasion of Ukraine, the conflict in Israel-Gaza, and recovered sanctioned assets alleged to be held for the benefit of Russian oligarch, Petr Aven, the first recovery of its kind in the UK. During this period, the UK issued 18 sanctions packages, targeting 76 entities, 50 individuals and 59 ships.
The newly elected Labour government has promised to clean up the UK’s reputation as a centre for ill-gotten gains. In the lead-up to the election, now-Foreign Secretary David Lammy declared that, “Fighting kleptocracy will be a focus of the next Labour Foreign Office”.
The new government has continued to use sanctions to deter violations of international law in Ukraine and Israel-Gaza. Following amendments to sanctions regulations in July 2024, the Russia sanctions regime now provides for the targeting of ships, as well as entities and individuals. This is to target Putin’s ‘Shadow Fleet’ – 600 aging tankers that are used to circumvent sanctions on Russian oil. Since those regulations came into force, 59 fuel tankers have been sanctioned. Additionally, the UK has targeted two entities affiliated with the proscribed terrorist organisation the Wagner Group – Diamville and Wood International Group Sarlu – as well as 16 members of the notorious Russian cyber-crime gang Evil Corp, and members of Russia’s disinformation network.
There have also been significant developments in the enforcement of the UK’s sanctions regime. The National Crime Agency secured, by way of consent order, the first-ever forfeiture of frozen funds, Starling Bank was fined by the Financial Conduct Authority for failures in its due diligence processes, a UK court made an interim order to remove a company director for sanctions breaches, and the Office for Trade Sanctions Implementation was launched. In a legal challenge, the UK Supreme Court granted permission to Eugene Shvidler to appeal a ruling that upheld sanctions against him.
The UK has imposed sanctions on a range of actors involved in the Israel-Gaza conflict. On 2 September the Government announced the immediate suspension of around 30 export licences to Israel, prohibiting the export of items used by the Israeli Defence Forces in the current conflict. Simultaneously, the Government sanctioned 13 Iranian individuals and seven entities accused of supporting armed groups intent on destablising Israel and developing ballistic missiles for attacks. On 15 October, the UK Government announced further sanctions, targeting three Israeli settler outposts, and four Israeli organisations in the West Bank linked to inhuman treatment of Palestinians.
Finally, the UK has used targeted sanctions against Belarusian penal colony commanders, allegedly responsible for acts of torture against political prisoners in Belarus, supporters of the proscribed terrorist organisation Al-Shabaab in Somalia following UN Sanctions Designations, and companies supporting the Myanmar regime.
Our most recent updates from May 2024 and January 2024 can be found here and here