Briefing

UK National Security designations – more restrictions, more screening, more complexity

Sanctions lists keep growing, with the UK, US and EU continuing to designate individuals and entities under programmes relating to Iran, Russia and Cuba on virtually a daily basis.

As well as the UK’s traditional country programmes, which focus on behaviour at the country level, the past few years have seen growth in the UK’s imposition of so-called thematic sanctions, which focus more on individual behaviour, including cyber activity, corruption and human rights abuses.

Keeping up to date with these programmes is a considerable challenge for commercial organisations, and new developments in the UK have the potential to further increase this challenge significantly. The UK has started to designate particular bodies under non-sanctions legislation, with the result that the designated bodies will not appear on the UK Sanctions List, unless they are separately designated under sanctions legislation.

Given the broad scope of the relevant prohibitions, and the risk of criminal penalties for non-compliance, persons who are subject to UK jurisdiction should be checking urgently to ensure that their processes are adequate to identify any matches against non-sanctions designations.

Background

The National Security Act 2023¹ seeks to address threats to UK national security from espionage, sabotage and persons acting for foreign powers.

Sections 31 onwards introduce the concept of foreign power threat activity, including (i) obtaining or disclosing protected information; (ii) obtaining or disclosing trade secrets; (iii) assisting a foreign intelligence service; (iv) entering, etc. a prohibited place for a purpose prejudicial to the UK; (v) sabotage; (vi) foreign interference: general; and (vii) obtaining material benefits from a foreign intelligence service.

In July 2026 the National Security Act 2023 was amended by the National Security (State Threats) Act 2026² in two key respects.

Firstly, section 33A was added, giving the Secretary of State power for the first time to designate bodies involved in foreign power threat activity.

Secondly, new offences were created, covering (i) supporting a designated body; (ii) assisting a designated body; and (iii) obtaining, etc. material benefits from a designated body.

These offences are broader than the offences under sanctions legislation, as they include conduct such as inviting support for a designated body, arranging a meeting for a designated body and addressing such a meeting.

However, they also include offences which are very similar to the asset freeze provisions under the sanctions legislation, namely (i) providing, or providing access to, information, goods, services or financial benefits (whether directly or indirectly); and (ii) receiving a material benefit (including financial benefits, anything which has the potential to result in a financial benefit, and information) from or on behalf of a designated body.

Penalties for breach can include up to 14 years’ imprisonment, an unlimited fine, or both.

UK designations

The first designations were made with effect from 17 July 2026³, as a result of which the following are now UK designated bodies:

the Islamic Revolutionary Guard Corps (IRGC) (Sepah-e Pasdaran-e Enghelab-e Eslami);
the Islamic Movement of Companions of the Right (IMCR) (Harakat Ashab al-Yamin al-Islamiyah), together with alternative names (i) the Islamic Movement of the People of the Right Hand; and (ii) the Islamic Movement of the Companions of the Righteous;
the Main Intelligence Directorate of the General Staff of the Armed Forces of the Russian Federation Volunteer Corps (Glavnoye upravleniye General’nogo shtaba Vooruzhonnykh sil Rossiyskoy Federatsii Dobrovol’cheskii korpus) (GRU VC).

The Explanatory Memorandum⁴ explains why each body was designated, as well as the over-arching objective of protecting the safety or interests of the UK by disrupting the designated bodies through criminal offences targeting those who work with and support them.

Impact

We would not generally expect commercial organisations to have engaged directly with any of the designated entities mentioned above, particularly as the IRGC has already been sanctioned in its entirety by the UK.

As a result, these new designations may have limited immediate impact for most commercial organisations.

The broader significance, however, is that commercial organisations need to take this opportunity to check that their screening and compliance programmes are capable of capturing this new source of designations, to ensure that any future designations are promptly identified, and appropriate action can be taken without delay.

As ever, keeping up to date with this fast-changing landscape remains absolutely critical

HFW’s Sanctions Team has extensive experience assisting clients with sanctions due diligence, sanctions investigations, engagement with regulators, and managing the commercial and regulatory consequences of enforcement and sanctions disputes.

If you require guidance on any of the issues addressed in this briefing, or would like to discuss HFW’s work in this area, please do not hesitate to contact the authors.

Footnotes