Guidance

Global irregular migration and trafficking in persons sanctions: information note for non-governmental organisations

Published 22 July 2025

1. Introduction

The global irregular migration and trafficking in persons sanctions (GIM) regime was established on 23 July 2025 via the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025. The primary legislation underpinning the Regulations is the Sanctions and Anti-Money Laundering Act 2018.

The sanctions regime allows the UK government to impose sanctions to tackle people-smuggling, trafficking in persons and the instrumentalisation of migration for the purpose of destabilisation around the world.

The regime is not intended to target individual countries or individual migrants. Rather, it is intended to target those that exploit some of the most vulnerable in society, putting lives at risk for their own gain and profiting from the dangerous smuggling and trafficking of innocent people.

The measures which can be imposed under the GIM sanctions regime are travel bans, asset freezes, and director disqualifications.

This note provides further information about the GIM sanctions regime, including its purpose and scope, and the information required in considering designations. Its aim is to support understanding of the regime for those who may wish to submit information to the FCDO concerning specific designations.

The UK has a range of autonomous sanctions regimes, each with a different purpose and a different geographical or thematic scope. Anyone considering sending information to the FCDO concerning possible designations should consider which sanctions regime is most relevant.

2. Purpose and scope of the global irregular migration and trafficking in persons sanctions regime

The purpose of the GIM sanctions regime is to prevent and combat people-smuggling, trafficking in persons and the instrumentalisation of migration for the purpose of destabilisation. As set out in the regulations:

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;
2. ‘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;
3. ‘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 regulation 4 paragraph (3), subject to the condition set out in regulation 4 paragraph (4) of the Regulations.

Full definitions of these terms are set out in the Regulations.

3. Who can be designated

The GIM sanctions regime can be used to designate persons who are ‘involved’ in the activities mentioned above. An involved person could potentially be an individual, a corporation or an organisation. The Regulations set out that a person is an
‘involved person’ if:

1. the person is responsible for or engages in (or takes any action with the intention of engaging in) such an activity
2. 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
3. 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
4. the person:
   • 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
   • 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
5. 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:
   • such an activity, or
   • any profit or proceeds from such an activity
6. the person transfers or converts (or takes any action with the intention of transferring or converting), or facilitates (or takes any action with the intention of facilitating) the transfer or conversion of, any profit or proceeds from such an activity
7. the person provides (or takes any action with the intention of providing) financial services, or makes available (or takes any action with the intention of making available) funds, economic resources, goods or technology, that could contribute to such an activity, or provides financial services relating to such making available
8. the person provides (or takes any action with the intention of providing) financial services, or makes available (or takes any action with the intention of making available) funds, economic resources, goods or technology, to a person whose conduct falls within sub-paragraph (a) or (b)
9. the person is involved in (or takes any action with the intention of being involved in) any other action, policy, activity or conduct which promotes, enables or facilitates (or is intended to promote, enable or facilitate) such an activity
10. the person is responsible for the investigation or prosecution of such an activity and intentionally or recklessly fails to fulfil that responsibility
11. the person uses (or takes any action with the intention of using) threats, intimidation or physical force to interfere, or otherwise interferes (or takes any action with the intention of interfering), in any law enforcement or judicial process in connection with such an activity
12. the person contravenes or circumvents (or takes any action with the intention of contravening or circumventing), or is involved in (or takes any action with the intention of being involved in) assisting the contravention or circumvention of any relevant provision.

Under the Regulations, a person is also an ‘involved person’ if the person:

• is owned or controlled directly or indirectly by a person who is or has been so involved
• is acting on behalf of or at the direction of a person who is or has been so involved, or
• is a member of, or associated with, a person who is or has been so involved

Decisions about designations will be taken on a case-by-case basis. The government has published a policy note on factors that it is likely to take into account in considering whether someone should be designated under the sanctions regime.

4. Legal tests

The Regulations set out the test that must be met before a person can be designated:

That there are ‘reasonable grounds to suspect’ that the person is an ‘involved person’ (ie connected to the activity in one of the ways set out above).

5. Information checklist

In considering designations, the following information is required:

5.1 What is the activity that justifies the application of sanctions?

Identification of activity that constitutes people-smuggling, trafficking in persons and the instrumentalisation of migration for the purpose of destabilisation under the Regulations.

5.2 Who is the person?

For example, name (including any aliases), title and other identifying information.

5.3 How, and to what extent, is the person involved in the activity?

In what way(s) is the person an ‘involved person’ under the Regulations (as set out above)? For example, was the person directly responsible for, or engaged in people-smuggling, or did they facilitate or support it, or conceal evidence of it?

Each of these elements must be sufficiently evidenced in order to demonstrate that there are ‘reasonable grounds to suspect’ that the person is an ‘involved person’.

6. Contact

This information note is to provide background information for the new GIM sanctions regime.

If any person or organisation wishes to submit information to the FCDO concerning possible designations under the GIM sanctions regime they may do so to fcdo.correspondence@fcdo.gov.uk.

Please ensure that any information provided is accurate, necessary and proportionate. All reasonable steps should be taken to ensure that the information is verified or verifiable and from a trusted source, and only information relevant to the proposed designation should be provided.

6.1 Confidential information

Any information provided in the expectation that it will be treated as confidential must be marked clearly as such. However, please note that all information provided to the FCDO is subject to UK legislation. This means there may be circumstances where we nevertheless have to release information under, for example, data protection or freedom of information regimes or in the context of litigation. Therefore, please carefully consider what information is provided and any risks if that information were to be disclosed.

The FCDO will be unable to provide comments, updates or feedback on proposed designations, evidence or other information that has been submitted.