Russian oil tanker vessel

Sanctions in a Contested World: the UK Publishes its First Ever Sanctions Strategy   

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

Targeted sanctions remain the UK Government’s preferred tool to respond to urgent human rights crises. In the past months, it has used its sanctions powers to  challenge Myanmar military-linked enterprises and infantry divisions responsible for ongoing repression and attacks against civilians,  Israeli extremist settlers in the West Bank, and Russian individuals heading up the Arctic penal colony where Alexei Navalny was killed. 

The legitimacy of targeted sanctions as a tool for international accountability hinges on their consistent and fair use. Yet, to date, some of the most notorious human rights abusers and corrupt actors, including in Iran, Nigeria, Sudan, China, or Egypt, have not been sanctioned by the UK. It also requires robust enforcement to ensure those targeted cannot exploit loopholes by seeking refuge in other jurisdictions. To address these concerns, today the UK Government published its first ever sanctions strategy, Deter, Disrupt and Demonstrate – UK Sanctions in a Contested World which sets out the UK Government’s approach to sanctions, reflecting several recommendations advocated for by REDRESS. 

The strategy outlines evolutions in the UK’s use of sanctions and explains how the UK Government intends to make UK sanctions more effective by building coalitions with allies, deepening engagement with civil society, and strengthening sanctions enforcement. It stresses the UK’s commitment to use sanctions to address serious human rights violations and corruption and pursue all lawful routes to use sanctioned Russian assets to support Ukraine. Below we set out the main points in the strategy along with our recommendations to improve sanctions policy in the UK: 

Impact of sanctions

The strategy emphasises that sanctions remain a critical instrument of the UK’s foreign, national and security policy. Sanctions are meant to: 

  • deter and disrupt continued or future malign activity; 
  • demonstrate the UK’s readiness to defend international norms; and  
  • be deployed selectively and proportionately as part of wider diplomatic, legal and policy efforts. 

In  ‘Evaluating Targeted Sanctions: A Flexible Framework for Impact Analysis’, REDRESS recommended that countries using sanctions should ensure that designations form part of a larger, coherent foreign policy but warned that by selectively choosing the types of abuses to engage with, governments could undermine sanctions’ role as a tool for accountability and change. As noted in our January 2024 Quarterly Update, the vast majority of UK’s sanctions targets to date are located in a country the UK neither considers to be a partner or ally. To avoid the charge of double-standards, the UK must ensure that it deploys its targeted sanctions regimes fairly and consistently against perpetrators of human rights violations and corruption, wherever they may be located.  


Stressing the importance of international coordination, the strategy notes that ‘sanctions work best when multiple countries act together’ to amplify impact and close loopholes. These statements echo recommendations advanced by REDRESS in our reports, Multilateral Magnitsky Sanctions at Five Years, and Evaluating Targeted Sanctions: A Flexible Framework for Impact Analysis, including that jurisdictions must strengthen their use of Magnitsky-style sanctions programs and better coordinate their responses to human rights abuses and corruption.  

Collaboration with civil society

In a welcome development, the strategy picks up on REDRESS’ recommendation for governments to maintain open and active consultation with victims’ communities, civil society organisations and activists. Specifically, the strategy asserts that the UK “work[s] with NGO coalitions in areas such as human rights and anti-corruption, including receiving verifiable information to strengthen our evidence base for targeted sanctions”. Despite this commitment, REDRESS notes that civil society organisations were not consulted on the strategy itself.   

Sanctions implementation and enforcement

Section 5 and Annex 3 of the strategy emphasise the UK Government’s commitment to strengthen sanctions enforcement and list a series of developments to further this goal, including: 

  • major investment in building lasting sanctions capability across government; 
  • the creation of the Office of Trade Sanctions Implementation; and  
  • more support for UK enforcement agencies to investigate and prosecute the most serious sanctions breaches.  

REDRESS has repeatedly raised concerns about insufficient resourcing, compounding failures in sanctions enforcement by the Treasury’s Office for Financial Sanctions Implementation (OFSI). Since April 2022, OFSI has imposed only two fines totalling £45,000 despite receiving at least 463 reports of suspected breaches of targeted financial sanctions in 2022-2023 (excluding oil price cap and counter-terrorism breaches). It remains to be seen whether the Government’s increased focus on combatting sanctions evasion will succeed in reversing this disappointing track record and ensure UK sanctions are properly enforced and complied with.  

Confiscation of Russian sanctioned assets

The UK’s response to Russia’s invasion of Ukraine features heavily in the strategy. With over 1,200 sanctions having been imposed against Russian individuals and entities since February 2022, the Government is now increasingly turning its attention towards the confiscation of Russian sanctioned assets to support Ukraine. The strategy notes that the Government is “pursuing all lawful routes through which sanctioned Russian assets can be used to support Ukraine”, including by developing a voluntary process whereby sanctioned individuals may apply for sanctioned funds to be released for the express purpose of supporting Ukraine’s recovery. REDRESS welcomes that the UK Government has begun to connect the dots between sanctions and asset recovery. REDRESS has long advocated for the UK Government to facilitate the confiscation of sanctioned assets and repurposing of funds derived from sanctions evasion to fund reparations for victims.  

It is high-time for the UK Government to operationalise its promised ‘voluntary donation mechanism’. In an open letter to Prime Minister Rishi Sunak, REDRESS called on the UK Government to urgently resolve the deadlock over the sale of Chelsea Football Club to show the possibility of such mechanism being set up and ensure funds are used to meet the urgent needs of survivors of the conflict. Voluntary diversion of frozen assets can present a practical solution for making funds available for victims. Yet, any such mechanisms must ensure that a substantial percentage of donated funds are delivered as reparations in consultation with survivors and include proper oversight and due process.  

Oversight and due process

Section 4 of the strategy briefly addresses the measures built into the UK sanctions system to safeguard due process rights, including the right to legal challenge under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). REDRESS has argued that these provisions are insufficient to protect the rights of the sanctioned individuals and ensure proper scrutiny and Parliamentary oversight of the Government’s targeted sanctions regime. To address these gaps, in a recent submission to the UK House of Lords’ European Affairs Committee, we urged the UK Government to re-instate sections 24, 30 and 32 of SAMLA which were removed in 2022 by the Economic Crime (Transparency Enforcement Act) and introduce the recommendation by the Joint Select Committee on Human Rights to review designation decisions annually.  

Parliamentary oversight is especially important as the UK courts have interpreted the Secretary of State’s discretion to designate as being very broad. Amongst other things, the courts have shown considerable deference to the Secretary of State’s “expertise” in assessing certain aspects of the proportionality of designations (see Anzhelika Khan v The Secretary of State for Foreign, Commonwealth and Development Affairs).  

While the publication of the strategy is a welcome step towards transparency within the UK sanctions framework, REDRESS urges the UK Government to continue to put fairness, consistency, due process, and survivor’s needs at the centre of its sanctions decision-making processes.  Without these priorities at the forefront, the UK Government risks undermining the utility of sanctions as a tool for accountability and behaviour change.  

Photo by Tomes Romu (CC 3.0) of Russian oil tanker Mikhail Ulyanov. The Oil Price Cap (OPC) has targeted Russia’s most lucrative revenue stream – the export
of crude oil and refined oil products such as petrol and diesel.