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The UK government has announced a new sanctions regime targeting organised immigration crime. How does it ensure these new sanctions have teeth?

Follow the money, freeze the assets, and smash the gangs – it’s a beguiling vision, articulated by both UK Prime Minister Keir Starmer and Foreign Secretary David Lammy in a speech the latter gave in early January outlining how the UK government was going to target the gangs involved in organised immigration crime (OIC) by pursuing the finances of the criminals behind people-smuggling operations. Notably, Lammy announced a new standalone sanctions regime – the first in the world – aimed at disrupting the finances of these criminal networks, giving authorities the power to freeze their assets and disrupt their revenue streams where they are within the reach of UK sanctioning jurisdiction. 

Post-Brexit, the UK has been able to forge its own path in implementing new sanctions, including new thematic sanctions. New sanctions regimes have been introduced to tackle human rights abuses, cybercrime and corruption. Shortly before Christmas, the UK announced that it had sanctioned ‘three notorious kleptocrats’ to kickstart a new campaign against illicit finance. Migrant smugglers are next in the government’s sights.

Politicians of all stripes are drawn to sanctions for their hoped-for impact. Sanctions were going to have a crippling effect and push the Russian economy back to the Soviet era, we were told; sanctions were going to make the UK a hostile environment for the corrupt; and now sanctions will smash the gangs. But is the Labour government holding itself hostage to fortune like those that have come before?

Why Do We Need to ‘Smash the Gangs’?

It is estimated that migrant smuggling generates at least $10 billion a year worldwide. Over the last decade, OIC has become highly organised and professional, driven by the high potential profits and low risk for the criminal networks involved. High levels of forced displacement in recent years have created a rapidly growing market, with 2023 seeing the highest number of irregular border crossings into Europe since 2016. For those attempting to cross the Channel, the journey can be deadly, with over 200 people estimated to have died in the last 10 years. 

There are opportunities for a clear, well-designed and focused sanctions regime, working alongside other existing finance-based legal and law enforcement tools, to have a disruptive impact

OIC also has links to other types of serious and organised crime, facilitating sexual exploitation, modern slavery and violence. Criminal networks engaged in migrant smuggling not only earn a fee for every crossing but also receive ongoing revenues, with people forced to work as prostitutes or on cannabis farms. There is evidence of the proceeds of OIC being invested in other illegal activities including the trafficking of drugs and firearms. Leaving aside the political rhetoric, OIC – and the criminal networks that profit from it – undermine the security of the UK, exploiting vulnerable people without a care for people’s lives. 

Sanctions as a Response to Serious and Organised Crime

Sanctions have traditionally been used as a foreign policy tool, designed to influence and change unwanted or hostile behaviour from foreign adversaries. While the US has long used sanctions to target organised crime, the UK’s approach has been somewhat more hesitant; witness the recent Operation Destabilise, the National Crime Agency’s investigation into a multi-billion dollar Russian-speaking money laundering network, which led to the sanctioning of five individuals and four entities by the US Office of Foreign Assets Control – and yet there appears to have been no appetite or ability to follow suit with UK sanctions. The UK’s thematic sanctions regimes do not consider organised crime as a whole but deal only with specific types of activities – corruption, cybercrime, human rights abuses – some of which may have a nexus with organised crime and which, in the view of RUSI’s UK Sanctions Taskforce, have only had limited success. 

As the foreign secretary himself has written, irregular migration and OIC blur the lines between domestic and foreign policy. By their very definition, they are transnational crime threats. Likewise, the associated financial flows move across borders with seeming ease. The evidence suggests that the majority of the proceeds of OIC are laundered through the hawala system – a traditional, informal and highly effective way of moving value between jurisdictions based on trust. A 2022 report from the Financial Action Task Force sets out a typical way in which funds are moved: the migrant, or a family member, may visit a hawala dealer (also known as a hawaladar) to pay a fee in advance of the journey, likely handing them cash. The hawaladar will hold onto the funds and then disburse them to the criminal network once the journey has been completed, usually by contacting a hawaladar in the criminals’ country who will provide them with the same value in cash. Unlike other types of criminal activity, the criminal networks running the smuggling operations may have less control of the end-to-end process, but use a series of providers for different elements of the service, necessitating regular payments to suppliers which may often by sent via the hawala system too. While there are legitimate uses for the hawala system and it often provides the only money transfer solution – for example, for the transfer of migrant remittances – an inherent lack of oversight means that it is easy to exploit, whether to launder money, fund terrorism or evade sanctions. 

Putting Flesh on the Bones of an Idea

Targeting a system known for facilitating sanctions evasion with sanctions seems like it might be somewhat futile. However, there are opportunities for a clear, well-designed and focused sanctions regime, working alongside other existing finance-based legal and law enforcement tools, to have a disruptive impact. Policymakers are always quick to observe that sanctions are used ‘as part of a toolbox’ and not in isolation. Yet the government’s announcement was light on the detail of what other tools are in the box and how this symbiosis will work. Many questions posed by the eye-catching headlines have been left unanswered (as they are perhaps unanswerable), chief among them being: what is the government’s theory of change beyond press conference soundbites and signalling a wish for things to change? 

The history of sanctions is littered with cases of over-promising and under-delivering, where expectations and hopes for impact are misplaced

Furthermore:

• How will the existence of a sanctions regime impact the business of OIC based primarily beyond the reach of UK sanctions jurisdiction?
• Who, or what, will be targeted by the sanctions? Will it just cover people smuggling, or will it include the ongoing exploitation (which generates more revenue)?
• What about the facilitators of OIC, ranging from the manufacturers of small boats to the huge tech firms that allow their online platforms to be used to recruit victims? 
• What will be the threshold for designation? 
• Will the EU follow suit with its own sanctions on people traffickers? If it doesn’t, what impact can an autonomous sanctions regime in the UK have when so much of the financial activity related to OIC occurs outside the UK? 
• What is the interaction with existing thematic sanctions regimes given, for example, the close links between irregular migration and human rights abuses such as modern slavery? 
• How will enforcement action back up any sanctions that are issued – a challenge that has undermined the UK’s anti-corruption sanctions?

It is easy to critique the approach, but with so much promised by the prime minister and the foreign secretary, answering these questions matters.

A Sonic Screwdriver?

Sanctions are not the only tool arrayed by the government against OIC. It had already announced £150 million in extra funding for Border Security Command and an expansion of the use of Serious Crime Prevention Orders to impose restrictions on the travel and social media and phone usage of individuals suspected of being involved in OIC, but the faith placed in sanctions is striking.

The government’s announcement promised that it ‘will develop a new sanctions regime to cripple people smuggling crime rings and starve them of illicit finance fuelling their operations’ and thus ‘boost our ability to prevent, combat, deter, and disrupt irregular migration and hold smugglers and their enablers accountable’. Let’s hope so, but the history of sanctions is littered with cases of over-promising and under-delivering, where expectations and hopes for impact are misplaced. The prime minister and his foreign secretary have their work cut out if this latest well-meaning initiative is not to wind up like so many before it.

© RUSI, 2025

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