Russia’s 2022 invasion of Ukraine led to a large expansion in the use of sanctions by the government, but also consumed most of its sanctions capacity. We have worked with civil society partners to highlight gaps in enforcement of the regime and apply pressure on government to improve its sanctions response.
Our press commentary included appearing on BBC Radio 4’s flagship PM programme to analyse new sanctions laws, contributing to a front-page story in the Financial Times highlighting poor enforcement of financial sanctions by the Office of Financial Sanctions Implementation and an investigation with The Times which showed that subsidiaries of sanctioned companies can still sponsor UK visas.
Our briefings to Parliament were picked up by the Foreign Affairs Committee which reflected some of our key recommendations to improve sanctions implementation and enforcement in its 2022 report on illicit finance. We continuously monitored challenges to UK sanctions designations in the courts to look at how they are shaping the regime, including a key sanctions evasion case which exposed generous basic needs allowances from frozen funds for sanctioned oligarchs. This has informed our analysis of the UK’s first sanctions strategy and call for the government to address further questions in its long awaited Anti-Corruption Strategy.
In response to calls from parliamentarians to not only freeze oligarchs’ assets but seize them as well, we worked closely with colleagues at the Royal United Services Institute to brief parliamentarians on potential solutions. This included developing a proposal to improve the transparency of assets subject to sanctions and ensure concealed assets can be confiscated, which was taken up by the government and passed into law in December 2023.
This case study is taken from our 2022-23 Impact Report which can be downloaded here.
