On 15 October 2026, the UK introduced an expanded human rights sanctions regime, via the UK’s new Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 (the “2026 Regulations”). The 2026 Regulations revoke and replace the Global Human Rights Sanctions Regulations 2020 (the “2020 Regulations”).
These reforms notably enable the UK to impose sanctions for serious violations of international humanitarian law, as well as for obstructions of humanitarian assistance and conduct that seriously violates a person’s right to liberty and personal security.
Background on UK human rights sanctions regime
The 2020 Regulations were introduced on 6 July 2020 under the Sanctions and Anti-Money Laundering Act 2018 (the “Sanctions Act”).
The 2020 Regulations enabled the Government to designate persons involved in activities which, had they been carried out by or on behalf of a state within the territory of that state, would amount to a serious violation by that state of certain human rights — including the right to life, the right not to be subjected to cruel, inhuman or degrading treatment, and the right to be free from slavery, servitude or forced and compulsory labour.
At the time of implementation, the UK Government initially targeted 47 individuals and 2 entities responsible for or involved in serious violations of human rights under the 2020 Regulations. The UK Government has designated numerous individuals and entities since, most recently on 8 September 2026.
Expansion to UK human rights sanctions regime
The 2026 Regulations widen the grounds that can lead to designation by introducing three additional criteria, notably:
- Activity that constitutes a serious violation of international humanitarian law;
- Activity that constitutes obstruction of the delivery or distribution of, or access to humanitarian assistance; and
- Activity which, had it been carried out by or on behalf of a state within that state, would amount to a serious violation of an individual’s right to liberty and security of person.
The 2026 Regulations also introduce a power to designate persons by description, in addition to designation by name as permitted under the 2020 Regulations.
The core sanctions powers under the 2026 Regulations otherwise remain consistent with those under the 2020 Regulations, comprising asset freezes, travel bans and director disqualification. Any designations made and licences issued under the 2020 Regulations will also remain in force.
Implications for Businesses
From a practical standpoint, companies do not need to introduce any major changes to their existing sanctions compliance protocols as a result of the 2026 Regulations. Counterparties should continue to be screened as usual.
The Government has provided guidance on the new regulations in an Explanatory Memorandum but is yet to update its statutory guidance on global human rights sanctions.
Please do reach out to our team if you would like to discuss any of the issues in this post.
