Sanctions at a Crossroads as U.S. Misuse Continues

Sanctions at a Crossroads as U.S. Misuse Continues

By Katherine Bartos, Legal Fellow

While targeted human rights and anti-corruption sanctions remain a crucial tool for holding perpetrators to account, designations have declined as authorities prioritise country-focused targeted sanctions regimes. In the United States, record low use of Global Magnitsky and related sanctions programmes coincides with the Trump administration’s increasing misuse of targeted sanctions to benefit its allies while it removes designations at an alarmingly high rate.

Despite the slump in designations, States continued to multilateralise their sanctions responses. The U.S. and the UK imposed sanctions on scam centres in Southeast Asia for serious human rights abuses, and the U.S., UK, and EU also sanctioned commanders and affiliates of the warring parties in Sudan, particularly focusing on the Rapid Support Forces for mass violations committed during the siege of Al-Fashir, North Darfur. In response to Iran’s non-performance of its obligations under the Joint Comprehensive Plan of Action, the UK and Canada reimposed sanctions on individuals linked to Iran’s nuclear development and ballistic missile programs. This followed coordinated action by the UK, France, and Germany to trigger the UN ‘snapback’ process to reimpose UN sanctions on Iran.

In the latest Global Sanctions Mid-Year Update, REDRESS, Human Rights First, the Open Society Foundation, the Raoul Wallenberg Centre for Human Rights, and the Australian Centre for International Justice examine developments in the use of targeted human rights and anti-corruption sanctions programmes across the U.S., UK, EU, Canada, and Australia from 1 July 2025 to 31 December 2025.

United States

The past year marked the lowest annual use of the U.S.’ global human rights sanctions regime on record. The Trump administration faced criticism for improper delisting of sanctioned individuals and violations of confidentiality under visa ban programs. It was also accused of misusing sanctions programs to benefit personal allies and target political enemies, as highlighted by the listing and subsequent delisting of Brazilian Supreme Federal Court justice Alexandre de Moraes. The U.S. also continued to utilise the recently introduced ICC sanctions program and imposed sanctions on over 130 individuals and entities for human rights abuses and corruption under an additional six country-specific and thematic sanctions programs.

United Kingdom

The UK maintained economic pressure on Russia by imposing sanctions on Russian intelligence units, major Russian oil companies, and shadow fleet vessels involved in sanctions evasion. The UK Supreme Court upheld sanctions designations in two parallel cases, finding that both Russia-related designations did not impede rights guaranteed by the European Convention on Human Rights and that they were ultimately lawful. The court’s reasoning is significantly deferential to the UK Government, finding that the relevant Ministers have “special constitutional responsibilities to respond to and contain Russia’s invasion of Ukraine” and “superior institutional competence to make the relevant assessment”. The UK also introduced a new sanctions regime addressing irregular migration and announced two batches of sanctions targeting people-smuggling networks around the world.

European Union

The European Union extended the EU Global Human Rights Sanctions Regime (EUGHRSR) until December 2026 and prepared a report on addressing impunity through EU sanctions. In responding to Russian aggression in Ukraine, the EU imposed its 18th and 19th sanctions package on Russia, and EU leaders agreed to provide a €90 billion loan to aid in Ukraine’s defence. However, EU leaders ultimately decided not to utilise frozen Russian assets to finance the loan. In addition to imposing sanctions on Russian nationals for human rights violations in detention centres under the EUGHRSR, the EU imposed sanctions on Russian prison officials and members of the judiciary for domestic human rights violations and on Russian-affiliated individuals and entities for information manipulation and malicious cyber-activities under other thematic sanction regimes.

Canada

The second half of 2025 saw a sharp drop in human rights sanctions designations by Canada’s new governmental administration. Designations related to gross human rights violations were made under the Special Economic Measures Act (SEMA) and the United Nations Act (UN Act) as opposed to the Justice for Victims of Corrupt Foreign Officials Act (the Sergei Magnitsky Law). Canada imposed sanctions on 16 individuals and entities related to destablilization efforts in Moldova. To promote Syria’s economic recovery, Canada eased restrictive measures on Syrian government actors and economic entities. Alongside other jurisdictions, Canada continued to apply pressure on Russia due to the war in Ukraine, lowering the price cap of Russian oil and designating numerous individuals, entities, and shadow fleet vessels under its Russia sanctions regime.

Australia

Australiaprimarily imposed targeted sanctions on individuals responsible for the repression of civil society in Russia and on entities that supplied ransomware infrastructure to criminals and malicious cyber actors. Alongside its allies, Australia imposed sanctions on Russian shadow fleet vessels to prevent sanctions circumvention and hinder the Russian war economy. In addition, the Australian Government introduced a new autonomous sanctions framework for Afghanistan under which it listed four senior Taliban officials.