Sanctions Legislation Update: Introduction of New Global Irregular Migration and Trafficking in Persons Regime

Published by	External Relations
Type	Sanctions
Date published	22 July 2025

1. On 23 July 2025 the UK Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 (the 'UK Regulations') will come into force, establishing a new sanctions regime for the purpose of preventing and combatting people smuggling, trafficking in persons, and the instrumentalisation of migration for the purpose of destabilising a country.

2. The UK Regulations provide that a person involved in these activities can be designated for any or all of the following purposes:

a travel ban
director disqualification
asset freezes and restrictions on making funds, financial services, and economic resources available to designated persons

3. To give effect to the UK Regulations in Jersey, the Minister for External Relations (the 'Minister') made the Sanctions and Asset-Freezing (Implementation of Global Irregular Migration and Trafficking) (Jersey) Amendment Order 2025 (the 'Amendment Order'), under Article 3 of the Sanctions and Asset-Freezing (Jersey) Law 2019 ('SAFL'). The Amendment Order will come into force on 23 July 2025.

4. Any designations, or changes to designations, made under the UK Regulations are effective immediately and automatically in Jersey under the provisions of SAFL and the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the 'Sanctions Order').

5. If you know or have reasonable cause to suspect that you are in possession or control of, or are otherwise dealing with, the funds or economic resources of a person designated for the purposes of an asset-freeze under the UK Regulations you must:

freeze such accounts, and other funds or economic resources without prior notice and without delay
refrain from dealing with the funds or economic resources or making them available (directly or indirectly) to such persons unless licensed by the Minister
report any findings to the Minister, together with any additional information that would facilitate compliance with SAFL, and
provide any information concerning the frozen assets of designated persons that the Minister may request. Information reported to the Minister may be passed on to other regulatory authorities or law enforcement agencies

6. The UK has published specific guidance on these Regulations which may be considered by Jersey persons alongside the provisions and modifications of Schedule 2 of the Sanctions Order. For example, when UK guidance refers to 'The Secretary of State' this should read as the 'Minister for External Relations'. Any reference to the UK or a part of the UK should be read as a reference to Jersey.

7. All reporting under the UK Regulations, as implemented in Jersey, should be made to the Minister at sanctions@gov.je.

Further information

8. The UK press release.

9. Further information on sanctions can be found on Government of Jersey and Jersey Financial Services Commission (JFSC) websites.

10. The UK Sanctions List on GOV.UK.

11. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK.

Enquiries

10. Non-media enquiries should be emailed to the Financial Sanctions Implementation Unit at sanctions@gov.je.