Promoting Accountability for UK Enablers of Human Rights Violations

By Natalia Kubesch,

REDRESS Legal Officer

Financial institutions, arms brokers, company directors, lawyers, accountants and other intermediaries often operate behind the scenes of violent conflicts and grave human rights violations. They facilitate transactions, move money, provide professional cover and profit from actors responsible for grave abuses that may amount to international crimes. Yet, there are concerns that these ‘enablers’ rarely face meaningful consequences for their role. In the UK at least, there are concerns that they operate with near impunity.

The UK already has many tools that could be used to address this conduct: targeted sanctions, criminal liability, asset recovery legislation, anti-money laundering frameworks, civil litigation and professional regulatory regimes all offer potential pathways to accountability. The underuse of these mechanism can result in enforcement efforts remaining fragmented and opportunities to build sustained pressure on enablers being missed. In addition, enablers may have extensive legal and financial resources at their disposal to ward off potential accountability efforts.

To explore how accountability gaps could be closed, REDRESS convened an expert roundtable on 10 March 2026, hosted by Amy Sander and Naomi Hart at Essex Court Chambers. The discussion focussed on identifying practical legal and regulatory pathways to hold enablers accountable and deter others in the UK from providing financial, professional or logistical support to perpetrators of serious human rights violations.

The roundtable brought together lawyers, investigators, journalists, civil society activists and law enforcement practitioners from across the public, private and non-profit sectors. Participants’ expertise spanned human rights law, corporate accountability, illicit finance, sanctions, corruption, public international law and modern slavery. By bringing these perspectives together, the discussion examined how existing accountability tools, both legal and non-legal, could be used more strategically to deter professional enablers of human rights violations and hold them to account.

Participants explored how criminal, civil and regulatory approaches could reinforce one another to increase pressure on enablers. This included examining the potential use of the Proceeds of Crime Act 2002 to target salaries, company profits and other financial benefits derived from unlawful conduct, alongside civil litigation strategies such as negligence claims and actions against corporate actors and directors. The role of targeted sanctions was also considered, particularly with regard to how they might complement other enforcement measures.

Participants also discussed the possibility of criminal prosecutions for aiding and abetting international crimes, including through the provision of financial or economic resources. Acknowledging the high evidentiary and mens rea thresholds required for such prosecutions, the group explored sanctions violations as a possible alternative pathway for criminal accountability.

Professional and regulatory accountability was another key strand of the discussion. Participants considered anti-money laundering, due diligence and source-of-funds obligations for regulated professionals such as solicitors and explored the strategic use of regulatory referrals or complaints. The discussion also acknowledged the risks involved in pursuing these pathways, including the potential for defamation claims or strategic lawsuits against public participation (SLAPPs).

At the same time participants emphasised that legal accountability may not always be realistic or immediate and may depend on prevailing enforcement priorities and political will. In such cases, participants highlighted the role that investigative journalism, strategic media engagement and parliamentary advocacy can play in exposing harmful conduct and generating pressure for action.

The roundtable marked the first initiative under a new REDRESS project examining the role of UK-based enablers in facilitating international human rights abuses including torture. The project seeks to deter professionals in the UK from engaging in enabling activities by drawing attention to the role of enablers in the UK, and encouraging accountability for their actions through policy, legal, and regulatory responses.

For more information about REDRESS’ work on financial accountability please contact: Lyra Nightingale at [email protected] or Natalia Kubesch at [email protected].

Photo: Pexels