UK sanctions: public officials & control

• In the complex landscape of international sanctions, a recent decision by the UK Court of Appeal has cast a spotlight on the definition of ‘control’ within the realm of UK sanctions.
• The ruling in Mints has significant implications for the application of sanctions, particularly concerning designated persons’ ability to exert control over entities, irrespective of direct ownership.

Sanctions, as wielded by states, represent a multifaceted tool in the realm of international relations. These measures are designed to exert pressure on specific entities or individuals, compelling them to alter their behaviour or policies in accordance with the objectives set by the imposing state or a coalition of states. Sanctions can take various forms, including economic, trade, financial or diplomatic restrictions, and are often deployed in response to actions deemed contrary to international law, human rights standards, or the broader interests of the imposing state or the international community.