Turning Sanctions Enforcement into Redress for Survivors
At their best, targeted sanctions are a powerful tool to protect people, uphold international law, and affirm the rights and dignity of those harmed by grave abuses. With a small but vital change to the law, the UK Government can ensure that sanctions enforcement delivers yet another essential outcome: providing redress for survivors.
Imagine the following scenario. A Russian oligarch with assets in the UK is designated under the UK’s Russia sanctions regime for his close ties to the Kremlin and support for Putin’s war against Ukraine. As a result, his assets are frozen. He then uses enablers to transfer ownership of his Kensington mansion to a family friend. His brother purchases a luxury vehicle on his behalf and makes his debit card available to the oligarch to use as he sees fit, including for extravagant shopping trips. UK authorities eventually investigate and prosecute the sanctions violations, recovering the criminal assets.
Under UK law, the story for victims ends there. The proceeds from selling the mansion, the luxury vehicle, and other recovered assets are absorbed by the UK government. Victims of the war that the oligarch has supported — survivors of enforced disappearance, torture, and sexual violence — don’t receive a penny. This is not a failure of enforcement or of the courts. It is a gap in the law which effectively leaves judges with no choice regarding the ordering of compensation. Currently, the court’s ability to award compensation to victims is unduly narrow and cannot respond adequately to so-called “complex” cases like the scenario outlined above.
REDRESS has proposed amendments to the Crime and Policing Bill which would offer judges an alternative. They would allow courts to direct a portion of confiscated assets towards public interest compensation, ensuring that funds recovered from sanctions offences can support victims of the harms those sanctions seek to prevent. Enforcement would then align even more strongly with the stated purpose of the UK sanctions programmes – for example, stopping serious human rights abuses.
This reform is grounded in a simple principle: survivors have a right to reparation under international law that must be realised. Even where the harm caused by sanctions violations is widespread or indirect, it must be redressed and survivors included in the justice process. REDRESS has heard from Ukrainian survivors and civil society groups who have voiced a strong preference for receiving forms of reparation that are paid for by Russia and its allies and enablers. This can be seen as a form of justice and a recognition of survivors’ inherent human dignity. By redirecting illicit proceeds to trusted international mechanisms that already support survivors, such as the Trust Fund for Victims or the UN Voluntary Fund for Victims of Torture, UK sanctions enforcement can translate into medical care, psychosocial support, and other meaningful assistance to those who most urgently need it.
That is why we are proposing amendments 417 and 419 to the Crime and Policing Bill, as set out in a new briefing. As the UK strengthens its sanctions enforcement response, this is a chance to ensure that accountability is not only about punishment, but also about repair. By making criminal assets work for victims, the government can help turn sanctions enforcement into a source of healing for those who need it most.
Read the briefing on our proposed amendments to the Crime and Policing bill here.
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