Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025

Lord Verdirame Excerpts

Wednesday 17th September 2025 Grand Committee

[Lord in Waiting/Government Whip (Lord Lemos) (Lab)]

Before I begin, I profusely apologise for making the Committee adjourn. I should have been here, and I was not. I have not got a good excuse, but I hope that everyone will accept my profuse apologies.

This instrument was laid on 22 July under powers in the Sanctions and Anti-Money Laundering Act 2018. The measures in the instrument, subject to the made affirmative parliamentary procedure, entered into force on 23 July.

The UK’s history of migration is a long and positive story—I am a migrant myself, so I know how positive it is—but today, we face a grave problem. Large numbers of individuals are undertaking dangerous journeys via irregular migration routes that risk their lives and undermine the rule of law. Irregular migration is a foreign policy issue as much as a domestic one. Smashing the gangs and addressing public concerns at home demands hard-headed action abroad. We are determined to confront this head-on, Defending human rights and protecting national and international security are our twin objectives.

People smuggling and trafficking are assaults on human dignity. These vile trades exploit the vulnerable, fuel organised crime and destabilise entire regions. As our national security strategy makes clear, they threaten peace, security and the very fabric of international co-operation. That is why irregular migration is a top priority for this department. Together with the Home Office, we have established a joint unit on international irregular migration to strengthen our efforts, deliver our strategy and drive results.

Sanctions are one of the most important foreign policy tools the UK uses to back our words with action. The UK now has 37 live sanctions regimes, with more than 4,000 individuals and entities designated. All designated individuals and entities appear on the UK sanctions list, which can be found on GOV.UK. We continue to use sanctions alongside all our other diplomatic tools to protect our citizens, uphold our values and defend international peace and security.

This particular sanctions regime is a landmark step, as it is the first dedicated regime of its kind anywhere in the world. It is designed to prevent and combat the networks that enable irregular migration and reflects deep collaboration across government from the Home Office to law enforcement and draws on the full breadth of our expertise. It enables us to strike at every link in the chain from source to destination. We can impose real costs on the callous groups and individuals who promote and profit from the inhuman trade in people’s lives. Sanctioned individuals will face serious consequences, including being banned from entering the UK, being disqualified from company directorships and having their assets frozen. The regime adds powerful new tools to our arsenal. It allows us to act against people smugglers and their enablers with the same force that we apply to terrorists, cybercriminals and kleptocrats. I hope that noble Lords will agree that that is evidence of how seriously we intend to tackle this problem.

This regime reflects our broader strategy, which is to use sanctions to deter and disrupt threats and malign behaviour, defend our values and protect our country. It will target individuals and entities wherever they are in the world, from operators in countries of origin to those who smuggle migrants across borders and those who enable, promote and profit from these dangerous journeys, including companies involved in small boat supply chains and organised immigration crime. No part of the smuggling infrastructure will be beyond our reach.

Crucially, the regime will also allow us to target hostile state-backed actors who seek to weaponise migration in order to destabilise the UK or our allies. On 23 July, the UK took action. We sanctioned 25 individuals and entities involved in people smuggling, from small boat suppliers in Asia and hawala money movers in the Middle East to gang leaders in the Balkans and north Africa, individuals such as Bledar Lala, who leads a smuggling ring that moves people from Belgium across the English Channel to the UK, and Muhammed Pirot, a hawala banker who controls payments from people being smuggled from the Kurdistan region of Iraq to Europe via Turkey.

These designations cover a range of activities: supplying boats; forging documents; facilitating illicit payments; and orchestrating smuggling operations. Each one represents a blow to the business model of exploitation. We will continue to monitor the effectiveness of the designations imposed so far, as well as any future designations, to ensure that they demonstrate our ability to target individuals and entities anywhere in the world, disrupt the activities of criminal networks and deter others from engaging in this vile trade.

Although we are proud to lead, we do not stand alone. People smuggling and trafficking are global concerns, and we are working with international partners to confront them together. That includes strengthening sanctions co-ordination, sharing intelligence and building joint responses to dismantle criminal networks. We welcome the news from EU President von der Leyen that she intends to put forward a new system of sanctions, specifically targeted at people smugglers and traffickers, for EU member states. We look forward to working with the EU and other key partners to smash the gangs and tackle irregular migration.

Sanctions are a powerful tool of foreign and security policy. UK sanctions are built on a transparent and robust legal framework—it is important to emphasise that—which was confirmed by the Supreme Court in July this year. However, there may be instances where activity by a person falls within the scope of sanctions and other relevant law enforcement and criminal justice powers. In these instances, we work closely with colleagues across Whitehall and in law enforcement to deconflict and ensure that appropriate tools are used. The FCDO will continue to play its full part in delivering the Government’s plan for change. This legislation and the designations that follow are proof of that commitment.

I apologise again for not being present on time and forcing the Committee to wait. I beg to move.

[Lord Verdirame (Non-Afl)]

My Lords, I thank the Minister for that introduction. I support the Government’s efforts in this area and appreciate the need for innovative policy solutions, but I have some questions about this statutory instrument.

To begin with, as the Secondary Legislation Scrutiny Committee noted, the Explanatory Notes and the Explanatory Memorandum are rather thin. We are creating the world’s first sanctions regime on irregular migration with a substantive statutory instrument, as one would expect, but with rather short explanations and without an assessment of the impact. Can the Minister tell us a bit more about the practical impact that the Government expect this new instrument to have on the control of irregular migration? As the Minister noted, there were 25 designations a couple of months ago, so, by this stage, the Government will have probably carried out some assessment of the impact of this new tool.

The Explanatory Memorandum says that this will be a global regime that will allow the United Kingdom to

“target relevant persons and entities wherever they are in the world”.

In accordance with that, Regulation 4 defines both people smuggling and trafficking in persons in terms that are not limited to unlawful entry into the UK. But are we really going to designate persons who are involved in people smuggling anywhere in the world? The legal regime may be global, but the policy scope has to be more defined. Is there some connection with the UK that would be a trigger for designations in the policy?

I notice also the remark of the Secondary Legislation Scrutiny Committee on the criteria for involvement not being included in the Explanatory Memorandum. It is important, when this instrument is implemented, to know exactly what the criteria for involvement are, but perhaps that is a problem that can be remedied with guidance published online in due course.

The memorandum mentions that sanctions for human trafficking have been adopted under the global human rights sanctions regime, but that regime was deemed to be inadequate. Can the Minister tell us a bit more as to why that regime was not fit for this purpose and why it was necessary to create a wholly new sanctions regime?

One of the purposes of the regulations is to prevent and combat the instrumentalisation of migration by state actors—the Minister referred to that. This is an interesting and important development, and I am glad to hear that the European Union is keen on this. This is where it is likely that the sanctions will target the political level of certain states—for example, the situation at the border between Poland and Belarus—whereas the other sanctions are likely to target more ordinary criminals, so to speak. Does the Minister agree that it is particularly important for this aspect of the new sanctions regime to ensure that there is international action and co-operation?

I have a final, more technical point. Regulations 6 and 7, under the “urgent procedure”, contain a list of states—the US, the EU, Australia and Canada—where individuals might be designated under similar sanctions and where we would adopt an urgent designation, in part based on those other designations. I was a little confused because I understood that no other states had a sanctions regime like this one. So, in what circumstances would that urgent procedure come to fruition?

[Baroness Hamwee (LD)]

My Lords, the Minister should not be too upset about his late appearance on the Front Bench, with trumpets blaring outside. It is surprising, given the nature of this building and with the conditions outside that we are seeing today, that it does not happen more often.

From these Benches, I will not oppose the sanctioning of criminals who seek to abuse and profit from people smuggling and human trafficking. However, I confess to a degree of doubt as to how effective they will be, given the evasive skills of criminals and, bluntly, whether the sanctions will matter to many of them. That may, in part, depend on having a personal or business presence in the UK. I hope that having this ambitious regime does not mean the diversion of resources from actions that may be more effective.