Disrupting Organised Crime: If You Can’t Beat Them, Sanction Them?

27 Nov 2025 12:24 PM

The increased use of sanctions against organised crime necessitates a deeper evidence base on how they can best be targeted – and supported through diplomatic engagement across the range of states involved.

In July 2025, the Foreign, Commonwealth and Development Office announced the UK’s first use of targeted sanctions against people-smuggling networks facilitating illegal migration to the UK. The announcement was billed as heralding the use of ‘innovative foreign policy approaches’ as part of the ‘world’s first’ sanctions regime of its nature. Only months later, in September, President of the European Commission Ursula von der Leyen vowed to follow suit:

We need a new system of sanctions specifically targeted at people smugglers and traffickers. To freeze their assets. To restrict their ability to move around. To cut off their profits. People smuggling is a horrible, criminal business, and no smuggler should be allowed to get away with it in Europe.

An Attractive Alternative

These developments form part of a wider trend. Over recent decades, targeted financial sanctions – that is, government-imposed asset freezes and travel bans – have become an increasingly mainstream response to organised crime. They have been wielded under different sanctions regimes against corruption; cybercrime; drug trafficking; transnational organised crime; and human rights abuse. Some of these catch-all categories of misconduct are so broad that one would struggle to think of any type of organised crime that cannot be addressed through sanctions.

This represents a significant expansion in the array of options at governments’ disposal. Sanctions cannot normally be used in relation to purely domestic crime, but once some cross-border aspect is present, they can be far easier to impose than any of the alternatives. In the UK, mere ‘reasonable grounds to suspect’ involvement in sanctionable activity are sufficient – as opposed to proof beyond reasonable doubt in criminal prosecutions or on the balance of probabilities in non-conviction-based asset forfeiture.

All of this goes to explain why sanctions can be intrinsically appealing as a response to complex, transnational organised crime threats. But they are also somewhat of a criminal justice anomaly because of the low evidentiary standard required. Furthermore, the powers to impose sanctions rest with foreign ministries, not courts or prosecutorial agencies. This creates perpetual uncertainty – are sanctions against organised crime primarily foreign policy tools or criminal justice ones?

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