What the Global Human Rights and Humanitarian Law Sanctions Regulations 2026 mean for your business
The UK has significantly expanded its global human rights sanctions regime, giving the government new powers to target individuals and businesses involved in serious violations of international humanitarian law, obstruction of humanitarian assistance and other human rights abuses.
The Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 (SI 2026/1071) came into force on 15 October 2026, replacing the Global Human Rights Sanctions Regulations 2020.
The changes expand the circumstances in which the UK government can impose sanctions, including against those who finance, facilitate, support or profit from serious violations. Companies may therefore face greater exposure through their commercial relationships, investments and supply chains, particularly when operating in countries affected by conflict, displacement or political instability.
What has changed under the new sanctions law?
The previous UK global human rights sanctions regime, introduced in July 2020, focused on serious violations of specific fundamental human rights, including the right to life, freedom from torture and freedom from slavery or forced labour. The new regulations retain those protections while considerably expanding their scope.
Serious violations of international humanitarian law
The government can now impose sanctions on those involved in serious violations of international humanitarian law (IHL), a framework of treaties, conventions and customary rules governing the conduct of armed conflict, including protections for civilians and others affected by war.
Previously, the UK could use humanitarian law violations as grounds for sanctions under certain country-specific regimes, including those covering Sudan, Syria, Myanmar and the Democratic Republic of Congo. The new regulations make these powers available globally, regardless of where the relevant violations occur.
Obstruction of humanitarian assistance
The regulations introduce grounds for designation relating to the obstruction of the delivery or distribution of, or access to, humanitarian assistance. This potentially extends the government’s ability to act against individuals and organisations involved in preventing aid from reaching populations affected by armed conflict.
Arbitrary detention and deprivation of liberty
The human rights criteria now expressly include serious violations of the right to liberty and security of person. This broadens the regime’s potential application to cases involving arbitrary detention, hostage-taking and other serious abuses affecting personal freedom.
Designation by description
The government can now designate people by description rather than exclusively by name. For example, a sufficiently defined category of people associated with an organisation involved in serious violations could potentially be designated without every individual being separately named. The regulations impose specific legal conditions on the use of this power.
This is particularly relevant to sanctions screening because compliance teams may need to assess whether a person falls within a designated description, rather than relying entirely on an exact name match.
Who could face sanctions under the new law?
One of the most significant implications for businesses concerns the breadth of activities that can bring someone within the scope of a sanctions designation. Under regulation 8, an individual or entity can be considered involved in relevant conduct through several different forms of participation.
These include directly engaging in prohibited conduct, facilitating or supporting it, concealing evidence, or obtaining financial or other benefits from it. The criteria also extend to people and entities owned or controlled by, acting on behalf of, or associated with those involved in the relevant activities.
Importantly, the regulations expressly cover the provision of financial services, funds, economic resources, goods or technology that may contribute to serious violations.
Under one of the designation criteria, the person providing these resources must know, or have reasonable cause to suspect, that they will or may contribute to the relevant activity. A separate criterion covers provision directly to a person responsible for or engaged in the activity, without expressly including the same knowledge requirement.
These are grounds on which the government may decide to designate someone. They do not mean that every company connected to an alleged violation automatically becomes sanctioned or has committed a criminal offence.
Nevertheless, they demonstrate why businesses need to examine the activities and relationships behind commercial transactions. A company could potentially face designation because of its involvement in supporting or benefiting from serious violations, even where it has not directly committed those violations itself.
Once designated, an individual or entity may be subject to an asset freeze, restrictions on the provision of funds or economic resources, director disqualification sanctions or a travel ban, as applicable. The financial prohibitions carry serious consequences for those who breach them, including potential criminal liability.
What does this mean for sanctions compliance?
The immediate change for businesses is more limited than the expanded designation powers might suggest. The regulations do not themselves add new individuals or entities to the sanctions list. Existing designations and licences under the 2020 regime continue under the replacement legislation. However the risk comes from how the government may use these expanded powers in the future.
Businesses could find that individuals, entities or commercial relationships previously outside the scope of UK sanctions become subject to restrictions. Sanctions screening therefore remains essential, particularly for businesses with international operations. However, simply checking whether a customer’s or supplier’s name appears on the UK Sanctions List may be insufficient.
Businesses must also consider ownership and control, indirect financial benefits, and the potential application of designations made by description. The regulations also include an urgent designation procedure which can enable the UK to act in coordination with sanctions imposed by the United States, European Union, Australia or Canada. Such designations are initially time-limited, with provisions allowing a further temporary period while the government assesses whether the ordinary designation criteria are satisfied.
This creates the possibility of relatively rapid changes to the sanctions position of an international business partner.
Why geopolitically risky areas require greater scrutiny
The new law has particular implications for businesses operating in conflict-affected or politically sensitive regions. Infrastructure development, reconstruction projects, mining, property development and financial services can all involve complex relationships with governments, politically exposed individuals and local commercial partners.
In these environments, it may be difficult to establish who ultimately controls a project, where its funding originates, or whether its commercial activities are connected to alleged human rights or humanitarian law violations according to the UK government.
However, the expanded regime means that businesses cannot assume that an otherwise lawful commercial contract carries no sanctions risk simply because the project is supported by a recognised government or the relevant parties are not currently designated.
The risks are therefore relevant to businesses operating in a wide range of international markets, especially where armed conflict has left unresolved disputes over displacement, ownership, reconstruction or access to humanitarian assistance.
The Chapman Taylor case: When commercial projects become human rights risks
The importance of assessing these risks is illustrated by the case of Chapman Taylor, a UK-based international architecture and planning firm involved in the redevelopment of Shushi, in Nagorno-Karabakh, Azerbaijan.
As VinciWorks previously reported, the firm became the subject of a complaint to the UK National Contact Point (NCP), the government-backed body responsible for handling complaints under the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. The complaint was brought by Avan Shushi Partnership, an investment partnership with interests in a hotel in the city.
Following the 2020 Nagorno-Karabakh war and the displacement of ethnic Armenians from the area, Chapman Taylor was contracted to develop a masterplan for Shushi’s redevelopment. The complainant alleged that the redevelopment plans affected properties belonging to displaced Armenians and raised concerns about the protection of cultural heritage and property interests.
It also alleged that Chapman Taylor had failed to conduct adequate human rights due diligence or use its influence with its Azerbaijani government clients to mitigate adverse human rights impacts.
Chapman Taylor disputed the characterisation of its role. The firm maintained that its responsibilities concerned the city’s masterplan, that decisions about implementation rested with its client, and that it had no involvement in the design or refurbishment of the complainant’s hotel.
In August 2025, the UK NCP accepted the complaint for further examination, finding sufficient grounds to examine the human rights due diligence concerns under the OECD Guidelines. Crucially, that initial assessment was not a finding that Chapman Taylor had breached the Guidelines. The proceedings also concern the OECD responsible business conduct framework, rather than an alleged breach of UK sanctions law. There has been no finding in the cited NCP decision that Chapman Taylor met the criteria for sanctions designation.
Nevertheless, the case provides a useful example of how a commercial project in a conflict-affected region can expose a professional services firm to significant scrutiny over its activities, relationships and human rights due diligence.
What should compliance teams do now?
The decision to impose sanctions ultimately rests with UK ministers applying the statutory criteria. This gives the government considerable discretion over when and against whom its expanded sanctions powers are exercised. Ultimately the application of sanctions remains a political decision, which can change when governments do.
Businesses with international operations should consider whether their existing sanctions and third-party risk management processes adequately reflect the expanded designation criteria.
In particular, compliance teams should:
- Review sanctions risk assessments: Identify countries, sectors, projects and business relationships with heightened exposure to armed conflict, serious human rights abuses or obstruction of humanitarian assistance.
- Strengthen third-party due diligence: Examine ownership and control, politically exposed persons, state-linked clients, intermediaries and the wider activities of commercial partners. Screening should account for indirect exposure and designations by description.
- Assess project-level human rights risks: For activities involving reconstruction, infrastructure or contested territories, consider whether a project could contribute to serious violations or benefit people involved in them. Document the basis for decisions to proceed.
- Monitor changes and respond quickly: Regularly review the UK Sanctions List and relevant international designations. Establish escalation procedures for new designations, adverse information or material changes in the geopolitical situation.
- Train relevant employees: Ensure procurement, finance, business development, legal and compliance staff can identify sanctions and human rights red flags, understand when enhanced due diligence is necessary and know how to escalate concerns.
Businesses should also consider contractual protections, including sanctions compliance warranties, notification requirements and the ability to suspend or terminate relationships if serious risks emerge. Where a transaction or business relationship may involve a designated person, firms must assess the applicable prohibitions and whether an exception or appropriate licence is available before proceeding.
Companies seeking opportunities in emerging markets, post-conflict reconstruction or internationally sensitive projects must understand the political and human rights context in which they operate.
The new UK regulations potentially increase the consequences of involvement in serious violations, particularly where businesses or their commercial partners provide financial support, resources or other forms of assistance to those responsible. Effective sanctions compliance therefore requires businesses to understand their counterparties and the broader activities their commercial relationships support.
For compliance teams, that means integrating geopolitical risk, human rights due diligence and sanctions monitoring into decisions about where and with whom their organisations do business.
