On 10 June, the UK imposed targeted sanctions on two senior Israeli government ministers – Itamar Ben-Gvir and Bezalel Smotrich – under the Global Human Rights Sanctions Regulations 2020. The move, coordinated with Australia, Canada, New Zealand and Norway, was based on what the UK described as ‘repeated incitements of violence’ by the ministers against Palestinian communities in the West Bank. The sanctions include travel bans, asset freezes and director disqualifications.
This development marks a significant moment in the evolution of the UK’s sanctions policy, particularly in its application to officials of a close diplomatic partner. It also reflects a broader trend among western governments to use human rights-based sanctions in a more coordinated and expansive manner.
Reasons for sanctions
The government cited serious human rights concerns as the basis for the designations. According to the Foreign, Commonwealth & Development Office, both Ben-Gvir and Smotrich were sanctioned in their personal capacities for inciting and promoting violence that contributed to ‘serious abuses of the right of individuals not to be subjected to cruel, inhuman or degrading treatment or punishment’. The UK emphasised that it considered these actions not as isolated incidents but rather part of a pattern of inflammatory rhetoric and support for extremist settler violence in the West Bank.
The sanctions were announced in the context of a purported rise in settler violence. A UN report cited by the UK noted more than 1,900 attacks by extremist settlers against Palestinian civilians since January 2024. Foreign secretary David Lammy stated that the UK and its partners were ‘committed to protecting the viability of a two-state solution and human rights, including by challenging those inciting violence’.
Global Human Rights Sanctions Regulations 2020
The legal basis for these sanctions lies in the Global Human Rights Sanctions Regulations 2020, enacted under the Sanctions and Anti-Money Laundering Act 2018. This framework allows the UK to impose targeted measures – such as asset freezes, travel bans, and director disqualifications – on individuals deemed responsible for serious human rights violations.
Both ministers were designated as ‘involved persons’ under this regulation. The designations do not entail broader economic or diplomatic sanctions against Israel but are instead narrowly tailored to the individuals’ conduct. This approach reflects the UK’s increasing reliance on targeted sanctions as a tool for promoting accountability without severing diplomatic ties.
Implications for international regime
The decision to sanction sitting ministers of a close ally illustrates the growing use of targeted sanctions as a flexible foreign policy instrument. It demonstrates that such measures are no longer limited to adversarial states or non-state actors but can also be applied to individuals in democratic governments when their conduct is deemed to violate international human rights norms.
This case also highlights the increasing coordination among like-minded states in applying human rights-based sanctions. The joint action by the UK, Australia, Canada, New Zealand and Norway may reflect a broader shift toward multilateral enforcement of human rights obligations through non-economic, targeted measures.
Relevance for politically active individuals and stakeholders
The UK’s decision to impose sanctions on sitting ministers of a close ally carries significant implications for politically active individuals and those advising or engaging with them. It signals a shift in how international legal frameworks are being applied, moving beyond traditional state-to-state measures and toward a model that holds individuals personally accountable for conduct deemed to violate human rights norms. This development underscores that political office in an ally state no longer guarantees immunity from international scrutiny, particularly when public statements or actions are perceived to incite violence or contribute to abuses.
For elected officials, the case illustrates that rhetoric and policy positions – especially those made in public forums – can have consequences that extend beyond domestic political debates. The designation of Ben-Gvir and Smotrich was based not on direct acts of violence, but on their alleged incitement and support for actions that contributed to human rights violations. This sets a precedent for how political speech and leadership conduct may be assessed under international human rights regimes, even in democratic contexts.
Legal advisers and policy professionals must now consider the growing reach of targeted sanctions regimes when advising clients on international engagement, public communications and risk exposure. The extraterritorial application of such measures means that individuals may face restrictions on travel, financial transactions and professional roles in jurisdictions far removed from their home country. This is particularly relevant in an era where political discourse is increasingly global and subject to real-time scrutiny.
Conclusion
The decision to sanction these Israeli ministers under the Global Human Rights Sanctions Regulations 2020 signals a marked departure from the norm that one does not sanction one’s allies.
For politically active individuals and stakeholders, this development signals a need for heightened awareness of the legal and reputational risks associated with public conduct. As the international sanctions landscape continues to evolve, the implications of this case are likely to resonate far beyond the immediate context of the sanctions that were imposed.
James Clark is a partner and James Philippsohn an associate at Quillon Law, London
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