UK sanctions on Israeli settlers: what the new measures mean

UK sanctions on Israeli settlers: what you need to know

The UK Government has announced targeted sanctions against Israeli settlers and new trade, as well as other restrictions on goods and activities connected to Israeli settler activity in occupied areas. These measures carry significant implications for individuals with ties to sanctioned persons and for businesses operating in or trading with the affected territories. This article explains who has been targeted, the legal basis for the measures, and what they mean in practice.

What has the UK Government announced?

The UK Government has made two significant announcements concerning Israeli settler activity in the occupied Palestinian territories.

Individual sanctions on Israeli settlers

Under the UK’s Global Human Rights Sanctions Regulations 2020, the Government has designated a number of Israeli settlers, imposing asset freezes and travel bans on named individuals. The sanctions regime allows the Government to target individuals believed to be involved in serious human rights violations or abuses. In this case, the designated settlers have been identified as being involved in acts of violence, intimidation, and the destruction of property directed at Palestinian communities in the occupied West Bank.

An asset freeze means that all funds and economic resources belonging to, owned, held, or controlled by the designated person are frozen. It is a criminal offence for any person in the UK, or any UK national anywhere in the world, to make funds or economic resources available to or for the benefit of a designated person. A travel ban prohibits designated persons from entering or transiting through the UK.

Trade and other restrictions on occupied territories

Separately, the Government has announced a package of trade and other restrictions relating to goods and activities connected to Israeli settler activity in the occupied territories. These measures go beyond individual sanctions and target the economic infrastructure supporting settlement expansion.

The restrictions are intended to ensure that UK businesses and individuals do not contribute to or profit from settlement activity that the UK Government regards as illegal under international law. They are set to include restrictions on the import of goods originating from settlements, banning advertising or promotion of land and property in settlements and creating new designation powers to go after individuals and companies that support, facilitate or profit from illegal settlement activity.

How could these measures affect you?

These measures have practical consequences for a range of individuals and organisations.

Impact on individuals

If you have personal, family, or financial ties to any of the designated individuals, you could be directly affected. Making funds or economic resources available to a sanctioned person, even unknowingly, is a criminal offence under UK law.

Individuals with connections to the occupied territories should also be aware of the broader trade restrictions. Activities such as investing in settlement-linked enterprises, purchasing property in settlements, or providing services to settlement-based entities could carry legal risk.

Impact on businesses

UK and international businesses that operate in, trade with, or have supply chains connected to the occupied territories will need to review their operations carefully. The trade restrictions may affect the import of settlement-origin goods, and companies will need to ensure they are not inadvertently facilitating settlement activity.

Businesses should carry out thorough due diligence on their counterparties, suppliers, and customers to ensure compliance with the new measures. Financial institutions in particular face enhanced scrutiny and should review their exposure to settlement-linked transactions.

Compliance obligations

The new measures create a range of compliance obligations. Businesses and individuals must screen against the UK sanctions list, ensure that no dealings involve designated persons or their assets, and take steps to avoid involvement in restricted activities connected to the occupied territories. Failure to comply can result in serious criminal and civil penalties, including imprisonment and substantial fines.

Risks and common pitfalls

There are several risks and common mistakes to be aware of:

• Failing to screen: Not checking counterparties and business partners against the UK sanctions list is one of the most common compliance failures. Regular screening is essential.
• Indirect dealings: Sanctions apply not only to direct dealings with designated persons but also to indirect dealings, for example, through intermediaries, shell companies, or trusts. Assuming that a transaction is compliant simply because there is no direct contact with a sanctioned person is a dangerous mistake.
• Assuming extraterritorial limits: UK sanctions apply to all persons within the UK, all UK nationals wherever they are in the world, and all entities incorporated or constituted under UK law. The reach of these measures is broad.
• Ignoring the trade restrictions: Even where no individual sanctions apply, the broader trade restrictions may still affect business activities. Companies should not focus solely on the sanctions list and overlook the wider restrictions on settlement-linked goods and activities.
• Inadequate record-keeping: Businesses should maintain clear records of their due diligence processes. In the event of an investigation, being able to demonstrate that reasonable steps were taken to ensure compliance is critical.

The Gherson perspective

These announcements represent a significant development in UK foreign policy and in the Government’s approach to the use of sanctions. For individuals and businesses with connections to the affected areas, the practical implications are real and immediate. Early legal advice is essential to understand how the measures apply to specific circumstances and to put in place robust compliance frameworks.

The timing of these measures has been remarked upon by commentators, with the Times stating: “…it has not escaped the government’s notice that Labour now faces an extremely unwelcome by-election, in Corbyn-venerating north London, and against the Green Party leader Zack Polanski. Only a cynic would suggest the two things are related.”

Whatever the motivation behind this announcement, the UK Government has issued a clear signal of intent, suggesting that this is only the beginning of the UK’s response to the ongoing turmoil in the Middle East.

Frequently Asked Questions

Who has been sanctioned and why?

The UK Government has designated a number of Israeli settlers under the Global Human Rights Sanctions Regulations 2020. These individuals have been identified as being involved in serious human rights violations, including acts of violence and intimidation against Palestinian communities in the occupied West Bank.

What does an asset freeze mean in practice?

An asset freeze means that all funds and economic resources belonging to or controlled by the designated person are frozen. It is a criminal offence to make funds or resources available to a designated person, whether directly or indirectly.

Do the trade restrictions apply to all goods from the occupied territories?

The trade restrictions are focused on goods and activities connected to Israeli settler activity in the occupied territories. They are not a blanket ban on all trade with the region, but they do require careful due diligence to ensure compliance.

Could I be affected even if I am not in the UK?

Yes. UK sanctions apply to all UK nationals wherever they are in the world, and to all entities incorporated under UK law. If you are a UK national or operate through a UK-incorporated entity, these measures apply to you regardless of your location.

What should businesses do to ensure compliance?

Businesses should screen counterparties and supply chains against the UK sanctions list, carry out enhanced due diligence on transactions connected to the occupied territories, maintain comprehensive compliance records, and seek specialist legal advice where necessary.

How Gherson can assist

Gherson’s International Law and Sanctions Team are highly experienced in advising on sanctions compliance, international trade restrictions, and human rights law. 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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