The UK is to introduce a new sanctions regime to target organised people smuggling gangs and their financing in an effort to boost the UK's ability to "prevent, combat, deter and disrupt irregular migration and hold the perpetrators accountable".
In a speech on 9 January 2025, the UK Foreign Secretary announced the introduction of the new regime, said to be the first standalone regime in the world to target irregular migration and organised immigration crime. The details of the new measures, are yet to be published although the Government has announced that the Foreign, Commonwealth and Development Office is working with the Home Office and law enforcement to develop the measures which will seek to "[stem] finance flows at their source and deters smugglers from profiting off the trafficking of innocent people". The new measures are due to come into force in 2025.
Sanctions have often been used as a tool to support domestic and international policy priorities and have been used extensively for this purpose since the Russian invasion of Ukraine. Recent sanctions measures appear to suggest that the new UK Government is seeking to use sanctions to target illicit financial flows, whether from people smuggling or the illicit gold trade (designations announced in December under the Russia, Democratic Republic of Congo and Global Anti-Corruption regimes).
Although details of the new measures have not yet been announced, firms should continue to ensure that they have adequate sanctions screening tools in place, attuned to the sanctions risks of their particular business, and should continue to monitor developments and designations to ensure compliance.
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