A Quarterly Update: New Designations, Increased Enforcement, and the Inaugural UK Sanctions Strategy

By Isabelle Terranova, REDRESS Legal Fellow 


Since 23 January 2024, the UK Government has imposed 16 targeted sanction packages to oppose transnational repression and democratic interference on UK soil and to address human rights violations committed in Israel and Gaza, Russia, Sudan, and Myanmar. During the same period, the UK saw multiple sanctions firsts– the Foreign, Commonwealth and Development Office (FCDO) published its inaugural sanctions strategy, prosecutors brought the first charges for breaches of the UK’s Russia sanctions and the UK Court of Appeal handed down its first judgment consideringthe proper approach to sanctions challenges in the UK, in particular on proportionality grounds.” 

Key designations targeted individuals and entities acting on behalf of foreign States to exert influence in the UK, including Iranian officials and members of criminal gangs responsible for plotting attacks against Iranian dissidents and activists living in the UK and a Chinese State-sponsored hacking group targeting democratic institutions and electoral processes in the UK and US. The UK also issued multiple sanctions packages in relation to the conflict in Israel and Gaza. For example, in February and again in May the UK imposed sanctions against those responsible for inciting and perpetrating settler violence against Palestinian communities in the West Bank. In March the UK further announced asset freezes against two individuals linked to a news agency that supports Hamas and the Palestinian Islamic Jiha. Finally, on 18 April and 25 April the UK sanctioned Iranian military figures and actors within Iran’s drone and missile industries in response to Iran’s attack on Israel on 14 April 2024.  

The FCDO also continued to increase economic pressure on Russia, sanctioning six Russian individuals in charge of the penal colony where Alexei Navalny was killed, imposing more than 50 new sanctions to mark the two-year anniversary of Russia’s invasion of Ukraine, and issuing new prohibitions on the trade of aluminum, copper, and nickel produced by Russia. Further, to address ‘regional instability,’ the UK designated key Houthi actors coordinating attacks against international shipping in the Red Sea and their enablers, as well as businesses supporting the armed groups responsible for the conflict in Sudan. Additional sanctions were issued to address human rights violations in Myanmar and the Democratic Republic of the Congo, and to combat serious corruption in Uganda 

Nearly four years after the introduction of its Global Human Rights Sanctions Regulations, in February 2024, the UK Government published its first ever sanctions strategy, outlining the UK’s foreign policy priorities shaping the use of sanctions, including to address serious human rights violations and corruption around the world. A more in-depth analysis of the strategy, including a discussion of the REDRESS recommendations that it reflects, is available here. 

Between January and May, the UK also saw increased criminal and civil enforcement action. For example, on 22 January 2024, the National Crime Agency arrested the former mayor of Sevastopol and Russian Deputy Minister of Trade and Industry Dmitry Ovsyannikov and charged him with seven counts of circumventing sanctions and two counts of money laundering, marking the first Russia sanctions breach charges in the UK since Russia’s invasion of Ukraine in February 2022. Additionally, from January to March 2024, HM Revenue and Customs issued compound settlement offers totalling just over GBP £2.3 million to seven unnamed UK exporters. Throughout the quarter, the Courts also handed down judgements in multiple cases challenging sanctions. On 20 February 2024, the UK High Court rejected Anzhelika Khan’s challenge to her inclusion on the UK Russia sanctions list, concluding that the Secretary of State had struck a fair balance between the rights of Ms. Khan and her family and the interests of the community. On 27 February 2024, the UK Court of Appeal dismissed the appeals of Dalston Project & Sergei Naumenko and Eugene Shvidler, finding the sanctions to be proportional in both instances. Additionally, on 3 May 2024, the UK High Court found that, were it necessary to do so in the case, it would conclude that there is reasonable cause to suspect that A1 is owned or controlled by a designated person. 

Outside the UK, in recent weeks, both the EU and US took significant steps to permit the confiscation and transfer of Russian sovereign assets for the support of Ukraine. On 17 April 2024, the Parliamentary Assembly of the Council of Europe (PACE) unanimously adopted Resolution 2539– Support for the reconstruction of Ukraine (the Resolution) and on 24 April 2024, the US Congress passed the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (REPO / the Act). This legislation will not only enable significant sums of money to be made available as reparation for victims in Ukraine but will likely also have a broader impact on the international legal landscape on asset confiscation.   

Our most recent updates from September 2023 and January 2024 can be found here and here. 

Photo credit: Andrea de Santis/Unsplashed