UK Government imposes sanctions targeting migrant smugglers

Earlier this year, the UK Government announced the creation of a new sanctions regime targeting irregular migration and organised immigration crime (please see our previous blog).

On 23 July 2025, the UK Government imposed sanctions under the new regime for the first time. The sanctions targeted 20 individuals and 5 entities involved in people smuggling, against whom asset freezes, director disqualifications and travel bans have been applied. The statement of reasons, included in the financial sanctions notice, details the engagement in smuggling of persons, and/or being a member of or associated with a person involved in smuggling of persons.

The prohibitions are further explained in the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025, and include a ban on dealing with funds or economic resources owned, held or controlled by a designated person (Regulation 14) and making funds available directly or indirectly to a designated person (Regulation 15).

OFSI (Office of Financial Sanctions Implementation) also amended General Licence INT/2025/5632740 (Interim Basic Necessities for Designated Persons) and General Licence INT/2022/1679676 (Law Enforcement and Regulatory Authorities Asset Recovery) to include the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025.

How Gherson can help

At Gherson LLP, we are closely monitoring the progress of this sanctions regime and its implications.

Gherson lawyers have significant experience in advising on immigration and sanctions matters, including sanctions compliance. We can provide training for your staff, help you with developing new sanctions policies and assist you with advancing your existing programmes.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on X, Facebook, Instagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

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