Our Island Plan

Sanctions Update: Global Irregular Migration and Trafficking in Persons

Wednesday, 22 October 2025

This news release is issued to publicise the addition of thirteen entries under the Global Irregular Migration and Trafficking in Persons sanctions regime.

The Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 (S.I. 2025/902) have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 ('the Regulations'), which are made under the Sanctions Act 2024. This regime imposes financial sanctions, namely the freezing of funds and economic resources persons who are or have been involved in people smuggling, human trafficking or the instrumentalisation of migration for the purposes of destabilisation.

Individuals and entities who are designated under this regime are included on the UK Sanctions List.

Types of sanctions applicable under this regime:

  • Asset freeze
  • Immigration

On 22 October 2025 the Foreign, Commonwealth and Development Office updated the UK Sanctions List. This list provides details of those designated under sanctions legislation.

Addition

Thirteen entries have been added to the UK Sanctions List and are now subject to an asset freeze. Further information can be found in the Annex to this Notice.

What you must do

If you suspect a person or entity is a match to a person or entity included in the UK Sanctions List, and you hold or otherwise deal with funds or economic resources of that person:

  1. You must freeze the assets immediately

  2. You must review the information you hold for that person against the UK Sanctions List to ensure you do not have a false positive identification

  3. Do not deal with those assets or make them available to, or for the benefit of the designated person unless:
    • You have a legal exemption
    • You have a licence

  4. You must report the frozen assets to the FIU

If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.

Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.

Note: determining if a customer is on the UK Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on the UK Sanctions List.

Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance page.

Further information

Further information on the sanctions regime related to Global Irregular Migration and Trafficking in Persons and other sanctions related guidance can be found on the Sanctions and Export Control website on the Sanctions Guidance page.

Contact details for enquiries

If you require any further information or guidance, please contact the Sanctions Team on:

Telephone: +44 1624 648109
Email: sanctions@gov.im

Please note: We are unable to provide legal advice. You may need to seek independent legal advice.

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