A Rise in the Use of Targeted Sanctions and New Challenges to Designations in the UK: A Quarterly Update

by Natalie Lucas, Legal Officer


The UK’s targeted sanctions space has remained active throughout the summer of 2023 with a number of new designations as well as legal and policy developments likely to impact the operation of sanctions in the future.  

Key highlights include the UK’s announcement of sanctions in response to the ongoing conflict in Sudan, (the first since the military seized power in October 2021) as well as coordinated action between the UK, US and Canada in tackling corruption in Lebanon. Conflict-related sexual violence continues to be a priority focus for the UK with 31 individuals and entities across eight jurisdictions designated for their involvement in these violations.  

June and July also saw announcements of changes to the Iran and Russian sanctions regimes. Most noticeably, the UK announced new legislation allowing Russian sanctions to be maintained until compensation is paid to Ukraine and mandating that designated persons under the Russian regime disclose UK-based assets or face financial penalties or confiscation. It also introduced a new Iran sanctions regime, expanding the UK’s power to target Iran’s senior decision makers for hostile activities directed against the UK and its citizens. Effective financial accountability for perpetrators of serious human rights violations  has long been an area for which REDRESS has advocated for serious policy reform (read our Framework for Financial Accountability and Torture). However it remains to be seen how such changes will work in practice and if it will lead to meaningful reparations for victims and survivors.  

As the UK continues to exercise its targeted sanctions powers, court-based challenges and delisting requests have been on the increase. The past four months have seen several actions reach the High Court, most notably, the first challenge by an individual under the Russian sanctions regime arguing that the designation was a disproportionate infringement on European Convention-based human rights and constituted unlawful discrimination. In a major win for the government, the challenge was dismissed and the designation upheld. Divergence from positions taken by the European Court of Justice have also come to the fore, with the  High Court denying interim relief from designation against an individual who was sanctioned on the basis of his familial relationship with another designated person. As sanctioning jurisdictions continue to develop their sanctions policy, such differences between courts on the justification for designation will likely become more common place and a challenge to international coordination.  

As we head into the final part of 2023 and towards International Human Rights and Anti-corruption Day,  it remains to be seen how the UK will affect the changes it has announced to the Iran and Russian sanctions regimes. REDRESS urges the UK government to continue its use of targeted sanctions in response to urgent human rights crises, to maximise the impact of its actions by coordinating where possible with international partners and ensuring that such tools are used without fear or favour in States where the UK may otherwise have strategic interests. 

For our previous quarterly update, see here. 

Photo credit: Andrea de Santis/ Unsplashed