The Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025

Made: 21st July 2025

Laid before Parliament: 22nd July 2025

Coming into force: 23rd July 2025

The Secretary of State[^f00001] makes these Regulations in exercise of the powers conferred by sections 1(1)(c) and (3)(b), 3(1)(a) and (d)(i), 3A, 4, 9(2)(a), 10(2) to (4), 11, 12, 15(2)(a) and (b), (3), (3A), (3B), (4)(b), (5) and (6), 16, 17(2) to (5) and (8), 21(1), 54(1) and (2) and 62(4) and (5) of the Sanctions and Anti-Money Laundering Act 2018[^f00002].

Part 1 — General

Citation, commencement and extent

1

• (1) These Regulations may be cited as the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025.

• (2) These Regulations come into force on 23rd July 2025.

• (3) These Regulations extend to England and Wales, Scotland and Northern Ireland.

Interpretation

2

In these Regulations—

• “the Act” means the Sanctions and Anti-Money Laundering Act 2018;

• “arrangement” includes any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable (but see paragraph 12 of Schedule 1 (rules for interpretation of regulation 9(2)) for the meaning of “arrangement” in that Schedule);

• “conduct” includes acts and omissions;

• “director disqualification licence” means a licence under regulation 27 (director disqualification licences);

• “document” includes information recorded in any form and, in relation to information recorded otherwise than in legible form, references to its production include producing a copy of the information in legible form;

• “Treasury licence” means a licence under regulation 26(1) (Treasury licences);

• “United Kingdom person” has the same meaning as in section 21 of the Act (extra-territorial application).

Application of prohibitions and requirements outside the United Kingdom

3

• (1) A United Kingdom person may contravene a relevant prohibition by conduct wholly or partly outside the United Kingdom.

• (2) Any person may contravene a relevant prohibition by conduct in the territorial sea.

• (3) In this regulation, a “relevant prohibition” means any prohibition imposed by—

• (a) regulation 12(2) (confidential information),

• (b) Part 3 (finance), or

• (c) a condition of a Treasury licence.

• (4) A United Kingdom person may comply, or fail to comply, with a relevant requirement by conduct wholly or partly outside the United Kingdom.

• (5) Any person may comply, or fail to comply, with a relevant requirement by conduct in the territorial sea.

• (6) In this regulation, a “relevant requirement” means any requirement imposed—

• (a) by or under Part 7 (information and records), or by reason of a request made under a power conferred by that Part, or

• (b) by a condition of a Treasury licence.

• (7) Nothing in this regulation is to be taken to prevent a relevant prohibition or a relevant requirement from applying to conduct (by any person) in the United Kingdom.

Purposes

4

• (1) The purposes of the regulations contained in this instrument are to prevent and combat—

• (a) people smuggling;

• (b) trafficking in persons;

• (c) the instrumentalisation of migration for the purpose of destabilisation.

• (2) In paragraph (1)—

• “instrumentalisation of migration for the purpose of destabilisation” occurs where the government of a country (“X”), or other person who is in control of X or is otherwise responsible for administering the affairs of X, or a group backed by the government or a person who is in control of X, facilitates, encourages or assists (in each case whether by an act or omission)— the movement of an individual in X towards the border of X, an individual in X to travel, whether directly or indirectly, to any country other than X, the movement of an individual in a country other than X (“Y”) towards the border of Y, or an individual in Y to travel, whether directly or indirectly, to any country other than X or Y, for the purpose of causing the destabilisation of any country other than X;

• “people smuggling” occurs where a person facilitates (whether by an act or omission) with a view to obtaining (directly or indirectly) any gain or benefit— the unlawful entry into, the unlawful arrival in, or the unlawful stay in, a country of an individual who is not a national of that country or permanently resident in it;

• “trafficking in persons” involves the undertaking (whether by an act or omission) by a person (“B”) of one or more of the types of conduct specified in paragraph (3), subject to the condition set out in paragraph (4).

• (3) The types of conduct specified in this paragraph are the—

• (a) recruitment,

• (b) transportation,

• (c) transfer,

• (d) harbouring, or

• (e) receipt,

of any individual (“A”) by B.

• (4) The condition in this paragraph is that the conduct specified in paragraph (3) is undertaken—

• (a) for the purpose of exploitation of A, and

• (b) using—

• (i) coercive means, or

• (ii) where A has not yet reached the age of 18, any means.

• (5) For the purpose of paragraph (4)(b), the identity of the person who uses the means is irrelevant.

• (6) For the purpose of the definition of “trafficking in persons” in paragraph (2), any consent purportedly given by A to—

• (a) A’s recruitment, transportation, transfer, harbouring or receipt, or

• (b) the exploitation which is the purpose of A’s recruitment, transportation, transfer, harbouring or receipt,

is irrelevant.

• (7) A is not to be treated as having been trafficked under the definition of “trafficking in persons” in paragraph (2) if—

• (a) A has not yet reached the age of 18,

• (b) no coercive means are used, and

• (c) either of the conditions in paragraph (8) applies.

• (8) These are the conditions referred to in paragraph (7)—

• (a) the condition in this sub-paragraph is that—

• (i) A consents to the removal of an organ (see definition of “exploitation” in paragraph (9)), or

• (ii) if A is not able to give such consent, A’s parent, guardian or, if A is in the care of an organisation, a person representing that organisation consent;

• (b) the condition in this sub-paragraph is that—

• (i) A consents to being used to provide services of any kind (see definition of “exploitation” in paragraph (9)) regardless of whether A is rewarded for that use or not, and

• (ii) a reasonable individual aged 18 or over would not consider that A being used for that purpose amounted to exploitation.

• (9) In this regulation—

• “coercive means” means— the threat or use of force or other coercive behaviour; abduction, kidnap or false imprisonment; fraud or other deception; abuse of power or a position of vulnerability; the giving or receiving of payments to achieve the consent of a person who has control over an individual;

• “exploitation” includes— being subjected to slavery, servitude or forced or compulsory labour; being prostituted by another person or otherwise being subject to sexual exploitation; being subjected to force designed to induce that person to provide services of any kind; the removal of organs; the use of an individual under the age of 18 for the purpose of the provision of services of any kind;

• “unlawful arrival in a country” occurs where an individual commits, including by fraud or other deception, a breach or attempted breach of a law which has effect in any country and which controls, in respect of some or all individuals who are not nationals of the country or permanently resident in it, entitlement to arrive in that country;

• “unlawful entry into a country” occurs where an individual commits, including by fraud or other deception, a breach or attempted breach of a law which has effect in any country and which controls, in respect of some or all individuals who are not nationals of the country or permanently resident in it, entitlement to enter into that country;

• “unlawful stay in a country” occurs where an individual commits, including by fraud or other deception, a breach or attempted breach of a law which has effect in any country and which controls, in respect of some or all individuals who are not nationals of the country or permanently resident in it, entitlement to remain in that country.

• (10) For the purpose of paragraph (8), a person specified in paragraph (11) may only give consent if it is reasonable to do so having regard to all the circumstances of the case.

• (11) The persons specified in this paragraph are—

• (a) A,

• (b) A’s parent or guardian, or

• (c) if A is in the care of an organisation, a person representing that organisation.

Part 2 — Designation of persons

Power to designate persons

5

• (1) The Secretary of State may designate persons[^f00003] by name in accordance with regulation 6 (conditions for the designation of persons by name) for the purposes of any of the following—

• (a) regulations 14 to 18 (asset freeze etc.);

• (b) regulation 20 (director disqualification sanctions);

• (c) regulation 21 (immigration sanctions).

• (2) The Secretary of State may provide that persons of a description specified by the Secretary of State are designated persons in accordance with regulation 7 (conditions for the designation of persons by description) for the purposes of any of the following—

• (a) regulations 14 to 18;

• (b) regulation 20;

• (c) regulation 21.

• (3) The Secretary of State may designate different persons for the purposes of different provisions mentioned in paragraphs (1) or (2).

• (4) For the purposes of these Regulations, persons “designated under regulation 5” for the purposes of a particular regulation means—

• (a) persons who are designated by name under paragraph (1) for the purposes of that particular regulation, and

• (b) where the Secretary of State makes provision under paragraph (2) that persons of a specified description are designated persons for the purposes of that regulation, persons of that description.

Conditions for the designation of persons by name

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• (1) The Secretary of State may choose whether to designate a person under regulation 5(1) (power to designate persons by name) under—

• (a) the standard procedure, or

• (b) the urgent procedure.

• (2) Paragraph (3) applies where the Secretary of State chooses to designate a person under regulation 5(1) under the standard procedure.

• (3) The Secretary of State may not designate a person except where condition A is met.

• (4) Condition A is that the Secretary of State has reasonable grounds to suspect that that person is an involved person.

• (5) Paragraphs (6) to (8) apply where the Secretary of State chooses to designate a person under the urgent procedure.

• (6) The Secretary of State may designate a person where condition A is not met but conditions B and C are met.

• (7) A person ceases to be a designated person at the end of the period of 56 days beginning with the day following the day on which the person became a designated person unless, within that period, the Secretary of State certifies that—

• (a) condition A is met, or

• (b) conditions B and C continue to be met.

• (8) Where the Secretary of State makes a certification under paragraph (7)(b), the designation ceases to have effect at the end of the period of 56 days beginning with the day immediately following the period mentioned in paragraph (7), unless within that period the Secretary of State certifies that condition A is met.

• (9) Condition B is that relevant provision (whenever made) applies to, or in relation to, the person under the law of—

• (a) the United States of America;

• (b) the European Union;

• (c) Australia;

• (d) Canada.

• (10) Condition C is that the Secretary of State considers that it is in the public interest to make designations under the urgent procedure.

• (11) For the purposes of condition B, “relevant provision” is provision that the Secretary of State considers—

• (a) corresponds, or is similar, to the type of sanction or sanctions in these Regulations, or

• (b) is made for purposes corresponding, or similar, to any purpose of any type of sanction or sanctions in these Regulations.

• (12) In this regulation “involved person” has the meaning given in regulation 8 (designation conditions: meaning of “involved person”).

Conditions for the designation of persons by description

7

• (1) The Secretary of State may choose whether to designate persons under regulation 5(2) (power to designate persons by description) under—

• (a) the standard procedure, or

• (b) the urgent procedure.

• (2) Paragraph (3) applies where the Secretary of State chooses to designate persons under regulation 5(2) under the standard procedure.

• (3) The Secretary of State may not designate persons except where conditions A and C are met.

• (4) Condition A is that the description of persons specified is such that a reasonable person would know whether that person fell within it.

• (5) Condition C is that the Secretary of State has reasonable grounds to suspect—

• (a) in a case where the specified description is members of a particular organisation that the organisation is an involved person, or

• (b) in the case of any other specified description that any person falling within that description would necessarily be an involved person.

• (6) Paragraphs (7) to (9) apply where the Secretary of State chooses to designate persons under the urgent procedure.

• (7) The Secretary of State may designate persons where condition C is not met but conditions A, D and E are met.

• (8) The persons of the specified description cease to be designated persons at the end of the period of 56 days beginning with the day following the day on which the persons became designated persons unless, within that period, the Secretary of State certifies that—

• (a) conditions A and C are met, or

• (b) conditions A, D and E continue to be met.

• (9) Where the Secretary of State makes a certification under paragraph (8)(b), the designation ceases to have effect at the end of the period of 56 days beginning with the day immediately following the period mentioned in paragraph (8) unless, within that period, the Secretary of State certifies that conditions A and C are met.

• (10) Condition D is that the description of persons specified is of persons (or some persons) to which, or in relation to which, relevant provision (whenever made) applies under the law of—

• (a) the United States of America;

• (b) the European Union;

• (c) Australia;

• (d) Canada.

• (11) Condition E is that the Secretary of State considers that it is in the public interest to designate persons under the urgent procedure.

• (12) For the purpose of condition D, “relevant provision” is provision that the Secretary of State considers—

• (a) corresponds, or is similar, to the type of sanction or sanctions in these Regulations, or

• (b) is made for purposes corresponding, or similar, to any purposes of any type of sanction or sanctions in these Regulations.

• (13) In this regulation—

• “involved person” has the meaning given in regulation 8 (designation conditions: meaning of “involved person”);

• “organisation” includes any body, association or combination of persons.

Designation conditions: meaning of “involved person”

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• (1) For the purposes of regulations 6(4) (conditions for the designation of persons by name) and 7(5) (conditions for the designation of persons by description), an “involved person” means a person who—

• (a) is or has been involved in a relevant activity,

• (b) is owned or controlled directly or indirectly (within the meaning of regulation 9) by a person who is or has been so involved,

• (c) is acting on behalf of or at the direction of a person who is or has been so involved, or

• (d) is a member of, or associated with, a person who is or has been so involved.

• (2) For the purposes of this regulation a person is involved in a relevant activity if—

• (a) the person is responsible for or engages in (or takes any action with the intention of engaging in) such an activity;

• (b) the person facilitates, incites, promotes or provides support for (or takes any action with the intention of facilitating, inciting, promoting or providing support for) such an activity;

• (c) the person profits (or takes any action with the intention of profiting) financially or obtains (or takes any action with the intention of obtaining) any other benefit from such an activity;

• (d) the person—

• (i) receives, whether in whole or in part, funds, economic resources, goods, technology or services in relation to relevant criminality or which, whether in whole or in part, constitute payment for the people smuggling of a person (“A”) (or their value or any representation of their value) by any means, or

• (ii) transfers, whether in whole or in part, (or takes any action with the intention of transferring) those funds, economic resources, goods, technology or services (or their value or any representation of their value) by any means;

• (e) the person conceals or disguises (or takes any action with the intention of concealing or disguising), or facilitates (or takes any action with the intention of facilitating) the concealment or disguise of—

• (i) such an activity, or

• (ii) any profit or proceeds from such an activity;