The Global Human Rights and International Humanitarian Law Sanctions Regulations 2026

Published: Tue 13th Oct 26

Established a consolidated UK sanctions regime for human rights and international humanitarian law violations, replacing the 2020 regulations.

These Regulations establish a legal framework to impose financial, immigration, and director disqualification sanctions on persons involved in serious human rights violations, breaches of international humanitarian law, or the obstruction of humanitarian aid.

The Secretary of State is authorized to designate individuals or entities by name or description, triggering an immediate freeze on their funds and economic resources and prohibiting others from making resources available to them.

The measures apply to all persons within the United Kingdom and to United Kingdom persons operating anywhere in the world, with enforcement overseen by the Treasury and the Foreign, Commonwealth and Development Office.

Arguments For

The regulations state that the measures are intended to deter and provide accountability for serious violations of an individual's right to life, freedom from torture, and freedom from slavery.
The document asserts that sanctions are necessary to address serious violations of international humanitarian law and the obstruction of humanitarian assistance.
The legislation provides a legal framework for the UK to align its sanctions designations with those of international partners, including the United States, the European Union, Australia, and Canada under an urgent procedure.
Proponents may argue that the inclusion of director disqualification sanctions and information-sharing powers strengthens the enforcement and effectiveness of the UK's global sanctions policy.

Arguments Against

Legal scholars may question the broad scope of the 'urgent procedure', which allows the Secretary of State to designate persons before meeting the standard evidentiary threshold of 'reasonable grounds to suspect'.
Civil liberties organizations have previously raised concerns regarding the impact of asset freezes on the due process rights of individuals who may be designated based on confidential information they cannot fully challenge.
Financial institutions and 'relevant firms' may cite significant administrative burdens and potential legal risks associated with the mandatory reporting requirements and the duty to monitor ownership and control structures.
Humanitarian agencies have noted that even with licensing exceptions, sanctions regimes can create 'chilling effects' that delay the delivery of aid to high-risk zones due to bank compliance fears.

Part 1 General

Citation, commencement and extent

-(1) These Regulations may be cited as the Global Human Rights and International Humanitarian Law Sanctions Regulations 2026.

(2) These Regulations come into force on 15th October 2026.
(3) These Regulations extend to England and Wales, Scotland and Northern Ireland.

This section establishes the official name of the legislation and sets the start date for its legal powers as 15 October 2026.

It confirms that the regulations apply throughout the entire United Kingdom.

Purposes

-(1) The purposes of the regulations contained in this instrument are to deter, and provide accountability for, activities falling within paragraphs (2) to (4).

(2) An activity falls within this paragraph if it is an activity which, if carried out by or on behalf of a State within the territory of that State, would amount to a serious violation by that State of an individual's-

(a) right to life,
(b) right not to be subjected to torture or cruel, inhuman or degrading treatment or punishment,
(c) right to be free from slavery, not to be held in servitude or required to perform forced or compulsory labour, or
(d) right to liberty and security of person,

whether or not the activity is carried out by or on behalf of a State.

(3) An activity falls within this paragraph if it constitutes a serious violation of international humanitarian law.

(4) An activity falls within this paragraph if it constitutes obstruction of the delivery or distribution of, or access to, humanitarian assistance.

(5) An activity falls within paragraph (2), (3) or (4) if it is carried out-

(a) outside the British Islands and British overseas territories by any person, or
(b) in the British Islands or a British overseas territory by a person who is not a United Kingdom national or a person incorporated or constituted under the law of any part of the British Islands or a British overseas territory.
(6) In paragraphs (2) to (4) an 'activity' includes an omission.

The regulations define the specific types of conduct that justify the imposition of sanctions.

These include serious violations of basic human rights, breaches of international laws governing armed conflict, and blocking humanitarian aid.

These rules apply to actions taken anywhere in the world by any person, or actions within the UK by foreign nationals and entities.

Part 2 Designation of persons

Power to designate persons

-(1) The Secretary of State may designate persons by name for the purposes of any of the following-

(a) regulations 14 to 18 (asset-freeze etc.);
(b) regulation 20 (director disqualification sanctions);
(c) regulation 21 (immigration).

(2) The Secretary of State may designate persons by description for the purposes of any of the following-

(a) regulations 14 to 18;
(b) regulation 20;
(c) regulation 21.

The Secretary of State is granted the authority to list specific individuals or groups of people who will be subject to sanctions.

Designated parties can be targeted with asset freezes, bans on serving as company directors, and travel restrictions.

Conditions for designation of persons by name

-(1) The Secretary of State may choose whether to designate a person under regulation 5(1) (power to designate persons by name) under-

(a) the standard procedure, or
(b) the urgent procedure.

(8) Condition A is that the Secretary of State has reasonable grounds to suspect that that person is an involved person.

(9) Condition B is that relevant provision (whenever made) applies to, or in relation to, the person under the law of-

(a) the United States of America; (b) the European Union; (c) Australia; (d) Canada.

(10) Condition C is that the Secretary of State considers that it is in the public interest to make designations under the urgent procedure.

The government may use two different methods to sanction a person: the standard procedure, requiring evidence of involvement in violations, or an urgent procedure.

The urgent procedure allows for immediate sanctioning if the person is already sanctioned by the US, EU, Australia, or Canada, provided it is in the UK public interest.

Urgent designations are temporary and expire after 56 days unless the standard evidence threshold is subsequently met.

Part 3 Finance

Asset-freeze in relation to designated persons

-(1) A person ('P') must not deal with funds or economic resources owned, held or controlled by a designated person if P knows, or has reasonable cause to suspect, that P is dealing with such funds or economic resources.

(4) For the purposes of paragraph (1) a person 'deals with' funds if the person-

(a) uses, alters, moves, transfers or allows access to the funds,
(b) deals with the funds in any other way that would result in any change in volume, amount, location, ownership, possession, character or destination, or
(c) makes any other change, including portfolio management, that would enable use of the funds.

It is a criminal offence to handle, move, or use any money or property belonging to a sanctioned person.

This 'asset freeze' applies broadly to any action that changes the amount or location of the assets or allows the designated person to benefit from them.

Part 7 Information and records

Finance: reporting obligations

-(1) A relevant firm must inform the Treasury as soon as practicable if-

(a) it knows, or has reasonable cause to suspect, that a person-
(i) is a designated person, or
(ii) has breached a prohibition or failed to comply with an obligation under any provision of Part 3 (Finance) or regulation 30 (finance: licensing offences), and
(b) the information or other matter on which the knowledge or cause for suspicion is based came to it in the course of carrying on its business.

Banks, law firms, and other regulated businesses are legally required to report to the Treasury if they suspect a client is a sanctioned person or has broken sanctions rules.

Failure to report these suspicions is a criminal offence.

Part 8 Enforcement

Penalties for offences

-(1) A person who commits an offence under any provision of Part 3 (Finance) or regulation 30 (finance: licensing offences) is liable-

(d) on conviction on indictment, to imprisonment for a term not exceeding 7 years or a fine (or both).

Violating the financial sanctions established by these regulations can result in severe legal penalties.

The maximum sentence for the most serious breaches is seven years in prison, a fine, or both.

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