Testing the Limits: Expanding the Reach of UK Sanctions

10 Nov 2025 11:57 AM

A double-win before the UK Supreme Court should embolden the Foreign Office, if they can take the public with them.

In July, the UK Supreme Court ruled on twin appeals against sanctions imposed after Russia’s 2022 invasion of Ukraine. Unusual facts made these ‘test cases’ for UK sanctions: British-American billionaire Eugene Shvidler sought to have a freeze over his assets revoked while a company requested the release of a super-yacht from a London dock.

The court upheld the Foreign Office’s approach to sanctions, with four out of five justices finding the government’s actions ‘proportionate and lawful.’ The one dissenting judgment, from Lord Leggatt, gained attention for its principled and trenchant tone.

It also raised points of interest to sanctions watchers: 1) the harsher impact of sanctions on UK nationals; 2) the lack of clear principles and wide discretion in designations; 3) the ‘Orwellian’ use of sanctions to elicit public statements; 4) the peril of sanctions as show gestures; 5) the need for robust evidence.

Lord Leggatt’s observations, considered in turn below, provide a starting point for exploring unique features of UK sanctions policy and how these could be developed further.

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