A Quarterly Update: New Sanction Designations and the UK’s Efforts to Clamp Down on Sanction Evasion

Read our January Quarterly Update

By Natalia Kubesch (Legal Officer) and Isabelle Terranova (Legal Fellow) 

Since September 2023, the UK Government has imposed 12 sanction packages against human traffickers in Southeast Asia, arms dealers and financiers supporting Russia, Myanmar and Hamas, as well as those interfering with democratic processes around the world. Our new quarterly update provides an overview of recent developments in the UK’s use of targeted sanctions, including new efforts by the UK Government’s to clamp down on sanction evasion. 

A key highlight was the UK’s announcement of 46 human rights designations, issued alongside the US and Canada, on 8 December 2023. The action targeted nine individuals and five entities involved in human trafficking, forced labour and torture in Southeast Asia, as well as 32 individuals linked to the suppression of fundamental freedoms in Belarus, Haiti, Iran and Syria. This sanction package followed a raft of designations by the UK Government in September and October 2023 against senior Iranian decision-makers responsible for drafting and implementing Iran’s mandatory hijab law, arms dealers and financiers of the Myanmar military responsible for the repression of the civilian population in Myanmar and Russian officials involved in ‘sham elections’ in occupied parts of Ukraine.  

November and December 2023 also saw the UK Government using targeted sanctions against Hamas leadership and its financiers “in an effort to disrupt the groups’ acts of terror” and impose a travel ban on Israeli extremist settlers responsible for “targeting and killing Palestinian civilians”. Concurrently, in December 2023, the UK Government used for first time its new Iran sanctions regime – developed to respond to an escalation in threats from Iran – to designate seven Iranian individuals and one entity with links to Hamas and Palestinian Islamic Jihad. Nine of these targeted sanctions packages were coordinated with international partners, continuing the trend of increased coordination with international partners since our latest quarterly update. Notably, however, none of the designations imposed during the reporting period targeted any individuals or entities based in a jurisdiction the UK Government considers to be an ally or security partner. In a welcome development, the UK Government is increasingly turning its attention towards ensuring designated persons and their enablers cannot exploit loopholes by seeking refuge in other jurisdictions. In December 2023, the UK Government created a new unit responsible for enforcing UK trade sanctions – the Office of Trade Sanctions Implementation (OTSI) – and introduced new legislation to address Russian attempts to evade UK sanctions. Reinforcing these actions, in December 2023, UK also designated 46 individuals and entities responsible for “supplying and funding Putin’s war machine”, including foreign military suppliers exporting equipment to Russia.  

REDRESS has highlighted how widespread sanction evasion risks undermining the impact of sanctions as a tool for accountability and behavioral change in our report, Evaluating Targeted Sanctions. In our new briefing Innovative Avenues to Finance Reparation in the UK, we further urged the UK Government to increase resources for its sanctions enforcement bodies to effectively counter this risk.  

While continued coordination and increased focus on combatting sanctions evasion are promising developments, their long-term impact is yet to be seen. REDRESS continues to urge the UK Government to use its targeted sanctions regimes fairly and consistently against perpetrators of serious human rights violations and corruption, wherever they may be located. It should also strive to coordinate with international partners, ensure existing sanctions are complied with and increase resources for its sanctions enforcement authorities. 

Our previous Quarterly Updates from April 2023 and September 2023 can be found here and here.  

Photo credit: Andrea de Santis/ Unsplashed

For more information please contact our legal officer Natalia Kubesch on [email protected]