Submission to Foreign Affairs Committee sanctions inquiry, March 2025

Written evidence submitted to the Foreign Affairs Committee sanctions inquiry by Spotlight on Corruption and the International Lawyers Project.

Recommendations

1. All Chairs of Select Committees with a sanctions remit (including the Foreign Affairs Committee, the Intelligence and Security Committee, the Treasury Select Committee, the Home Affairs Committee and the Business and Trade Committee) should collaborate regularly – including through a joint inquiry – to ensure the ongoing scrutiny of sanctions.
2. Parliament should encourage the Government to form an independent expert panel – which includes anti-corruption expertise – with the ability to make recommendations on FCDO sanctions policy and targeting based on objective criteria in line with international law to ensure consistency, fairness, and credibility in applying sanctions.
3. The government should establish a sanctions transparency tracker that collates key data from across the UK sanctions landscape in a centralised public database to enhance public and parliamentary scrutiny of sanctions.
4. Parliament should review whether limitations in UK’s sanctions regulations reduce their applicability and usefulness, including the failure of the GAC regime to include corruption relating to abuse of function, trading in influence and illicit enrichment.
5. Parliament should explore whether the Government could benefit from more creative measures (in addition to the standard measures such as an asset freeze, travel ban and director disqualification) to help maximise the effectiveness of sanctions, such as a ban on designated persons using professional services in the UK.
6. Parliamentary committees such as the Foreign Affairs Committee should take oral evidence from law enforcement agencies on the potential benefits of using sanctions regimes and law enforcement tools in combination.
7. Parliament should interrogate the Government on how sanctions can be used to help deliver its missions, such as how a new green accountability regime could contribute towards making Britain a clean energy superpower.
8. Parliament should conduct a cross-committee inquiry into the UK’s Magnitsky style sanctions regimes for corruption and human rights abuses by the fifth anniversary of these regimes coming into force, at the very latest.
9. Parliament should push for the Government to introduce a legislative requirement to consider suggestions for sanctions designations made by certain Parliamentary committees, as in the US.

To read the full submission, click on the link below.