Client Alert 23 Jul. 2025
The full alert is available for download here.
The first designations under this new regime came into force on 23 July 2025.
The UK has launched a new sanctions regime, The Global Irregular Migration and Trafficking in Persons (Sanctions) Regulations 2025 (the “Regulations”).
It is aimed at targeting irregular migration and organized immigration crime.
Under the new Regulations, the Foreign, Commonwealth and Development Office (the “FCDO”) has the power to impose financial sanctions, namely the freezing of funds and economic resources, as well as travel bans into the UK, on those persons involved in people-smuggling and human trafficking. The regime also empowers the FCDO to impose sanctions on any financiers and companies found to be enabling such activities.
The Regulations entered into force on 23 July 2025. They were adopted pursuant to the UK Sanctions and Anti-Money Laundering Act 2018 through the made affirmative procedure, i.e., they entered into force before Parliament had considered them. However, to remain in effect, the Regulations will be debated and will need to be approved by both Houses of Parliament when they return from the summer recess.
The financial sanctions announced on 23 July 2025 designate 25 entities and individuals under the Regulations for their roles as gang leaders, key intermediaries and suppliers in the people-smuggling trade.
Twenty individuals and five entities have been designated under the new Regulations.
Individuals include gang leaders based in the Balkans and North Africa, seven Iraqi-linked individuals involved in trafficking, suppliers of maritime equipment used by smugglers to cross the English Channel, bankers involved in informal money transfer networks and procurers of fake documentation used by gangs.
The five designated entities include four gangs from the Balkans and North Africa and a small boat supplier in China, as listed below:
We can expect to see further designations under these Regulations in the future in order to further undermine and frustrate the operational capability of a wide range of organized immigration crime networks.
The full UK Sanctions List can be accessed here.
Economic Sanctions
Marc Hammerson
Partner
Mikhail Bychikhin
Counsel
London
+44 20 3430 3000
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