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

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?

What Place for Sanctions?

For all the appeal of organised crime-related sanctions, their novelty presents manifold challenges. In short, there is remarkably little understanding of how they can be best used, or what effects they are likely to have.

First, consider the establishment of organised crime-focused sanctions regimes. How are these decisions made and what, if anything, renders a criminal business model susceptible to the impact of sanctions?

The UK and EU forays into irregular migration sanctions are clearly dictated by the political imperative to address migrant smuggling. But politics aside, there is an argument that smugglers’ operations do rely on the ability to travel and maintain bank accounts in Britain or Europe. Cutting off their ability to do so could be game-changing, if effectively implemented.

By contrast, Russian cybercriminals are unlikely to hold bank accounts or spend much time in the UK. Still, a steady pace of joint sanctions designations by the UK, US and Australia, most recently in late November 2025, sends the message that those cybercriminals’ identities and activities are well-known to law enforcement and intelligence agencies. Compared to irregular migration designations, these sanctions must be predicated on an entirely different set of assumptions and expectations about how they will affect their targets.

Consider also US counternarcotics sanctions, one of the earliest iterations of an organised crime sanctions regime. In a rare example of a government-commissioned impact study, the US Office of Foreign Assets Control published in 2007 a detailed account of the effects of US sanctions on 21 major Colombian drug traffickers. Few such studies have been produced since, despite a progressive expansion in the scope of US sanctions against transnational crime. Meanwhile, neither the UK nor the EU maintains a dedicated sanctions scheme against either drug trafficking or organised crime writ large, which underscores the differences in approach among states.

Second, there is the issue of how individual targets are selected: in other words, how specific people smugglers, cybercriminals, drug traffickers and others end up on a sanctions list. Neither the criteria used (in other words, what makes for a good target?) nor the practicalities (for example, how is evidence collected?) are well understood. While the UK government has published a set of factors that guide its imposition of sanctions for corruption and human rights abuse, it has not done so across the board, nor have many other governments followed suit.

Third, whether a government is setting up a sanctions regime or deciding on individual listings, it will inevitably look for its designations to produce maximum impact. The impact of sanctions against organised crime is rarely examined systematically. Collectively, your authors have written the first two studies of this nature, focused on organised crime-related sanctions and corruption sanctions respectively. Far more work is required to form a body of reliable knowledge as to what these sanctions can achieve where the political will exists.

Fourth, one should pay far greater attention to the role of countries where targeted groups and individuals are based. Their cooperation, or lack thereof, with sanctioning states can be determinative of the impact of sanctions. The attitudes of ‘home countries’ fall on a spectrum: from unambiguous opposition to foreign sanctions (think of Russia), through indifference all the way to, in some cases, being a driving force behind their implementation (as seen in the past in Colombia). How overseas cooperation is best secured is therefore a vital question, and one where the foreign policy dimension of organised crime-focused sanctions comes to the fore.

On this point, a range of novel questions arise from shifts in US sanctions policy under the Trump administration. A notable development has been the designation of transnational criminal networks as ‘foreign terrorist organisations and specially designated global terrorists’, a move made subsequently by other sanctioning states. This phenomenon throws up a range of uneasy conceptual and practical questions around how home countries can or should respond to such US sanctions against their citizens, which has not been studied at all.

Finally, crucial questions surround the nature of cooperation between states that impose sanctions; those where targets are based; and even third countries. Such cooperation is all the more critical in a fragmented international order – where agreement on multilateral sanctions use has increasingly fallen away. In this context, building coalitions of the willing is an ever-more critical determinant of organised crime-focused sanctions’ ability to achieve their desired ends.

Here, more than ever, what is needed is a nuanced engagement with what drives political will to use and cooperate with sanctions. In an increasingly complex world, effective diplomacy around organised-crime focused sanctions is likely to become ever more important. Our research over 2026 will seek to bolster the evidence base around these issues, in the framework of the Serious Organised Crime & Anti-Corruption Evidence (SOC ACE) Programme. One of its areas of focus is political will – and how diplomatic action can help organised crime-focused sanctions have the impact desired.

Beyond Symbolism

One of common pitfalls of all kinds of sanctions is the risk of a lack of the desired real-world impact. In a famous study of state-on-state economic coercion, Economic Sanctions Reconsidered, the authors concluded that sanctions succeeded in achieving stated policy objectives in less than 35% of cases. It is hardly surprising that sceptics frequently describe sanctions as symbolic projections of disapproval, devoid of any serious effect.

This is a risk for organised crime-focused sanctions, too. Unless governments develop a clear vision of what such sanctions can achieve, and how they are best deployed, their image as a fearsome tool may soon fade away – and even validate the sceptical view of sanctions as a tacit admission of impotence. To strengthen their use against threat actors from people smugglers to drug traffickers and cybercriminals, governments require a far stronger evidence base than is currently available. For the organised crime and sanctions research communities, interrogating the diverse interests, incentives, concerns and political considerations of the range of states involved is key to addressing these gaps.

© RUSI, 2025.

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