Human rights violations: EU, UK, and US regulations insights

The EU, UK, and US all use targeted sanctions – such as asset freezes and travel bans – to address serious human rights violations. 

In the EU, a major milestone took place with the introduction of Council Regulation (EU) 2020/1998 (restrictive measures against serious human rights violations and abuses) of December 7, 2020. For the first time, the EU had a vehicle for punishing serious human rights abuses – enabling quick, targeted response to various human rights violations, including torture, abuse, executions, and the arbitrary use of state power. Since then, the persons or organizations responsible can be punished independently of the country of their origin – an option not previously available.

With the Global Magnitsky Act, the USA created a legal basis for imposing sanctions for serious human rights violations already back in 2017.

In the UK, the Global Human Rights Sanctions Regulations 2020 was issued on July 6, 2020, to address human rights violations, imposing financial sanctions and travel bans for the first time on March 22, 2021. The sanctions were issued at the same time as those in the EU, Canada, and US – reflecting a coordinated move against human rights violations at the time (such as the oppression of the Uyghurs and other minorities in Xinjiang).

Since 2021, overall enforcement has expanded significantly, especially in supply chains. Extended regulatory scope now require companies to actively identify and prevent human rights abuses, particularly forced labour.

The EU operates a global sanctions framework that allows it to target individuals and entities involved in serious human rights abuses worldwide.

Key features:

• Applies globally (not country-specific)
• Targets individuals, organisations, and entities
• Includes asset freezes and travel bans
• Prohibits EU companies from making funds available to listed parties

What has changed since 2021?

• Expanded scope (e.g. trafficking, gender-based violence)
• Regular updates to sanctions lists
• Stronger coordination with international partners
• Continued extension of the regime (currently active through at least 2026)

Examples:

• Sanctions related to Russia (post-2022 escalation)
• Measures targeting abuses in Xinjiang (Uyghur population)
• Ongoing actions linked to Myanmar

Looking at the EU sanctions regulations reveals different objectives but an almost identical drafting of content for sanctions options: The approach seeks to dry up funds of the listed persons and organizations and restrict the persons from entering the EU.

The direct and indirect prohibitions on the provision of financial assets, economic resources, or technical assistance, which are primarily relevant for commercial enterprises, are therefore broadly defined to cover assets of all types.

In all these EU regulations, the sanctioned persons and organizations are listed in the annex.

Since the UK’s exit from the EU, the UK maintains its own autonomous sanctions regime, separate from the EU. 

Key features:

• Based on UK-specific legislation
• Closely aligned with EU and US in many cases
• Managed by the UK government and enforced domestically

What’s changed:

• Global Human Rights Sanctions Regulations since 2020
• Increased independent listings post-Brexit
• More flexibility to act quickly
• Continued coordination with allies, but not identical to EU policy

UK financial sanctions against individuals, entities, and organizations are consolidated in the UK Sanctions List, which encompasses all listings made under the UK Sanctions Act (Sanctions and Anti–Money Laundering Act 2018). 

For businesses, this means dual compliance is often required when operating across the EU and UK.

The US uses a broader and more comprehensive approach to human rights enforcement.

Key tools:

• Global Magnitsky sanctions (targeting individuals/entities)
• Trade restrictions and import bans
• Enforcement through financial systems and customs controls

Major development since 2021:

• Forced labour enforcement has become central
• The Uyghur Forced Labor Prevention Act (UFLPA) has taken effect in 2022
  
• The US now actively blocks imports linked to forced labour, especially from high-risk regions.

Business impact:

• Goods can be seized at the border
• Companies must prove supply chains are clean
• Enforcement is proactive, not reactive

Like the EU, the US has a range of sanctions programs with various objectives. The Global Magnitsky Act of 2017 provides a legal basis for punishing serious human rights violations.

Most US sanctions regimes are managed by the Office of Foreign Assets Control (OFAC) and consolidated in the Specially Designated Nationals List (SDN). 

You can learn more about the impact of the Uyghur Forced Labor Prevention Act (UFLPA) in this article.

Step 1: Screen all business partners

• Customers
• Suppliers
• Intermediaries

Step 2: Assess supply chain risk

Focus on:

• Geographic exposure
• Industry-specific risks
• High-risk materials or inputs

Step 3: Implement due diligence processes

• Ongoing monitoring
• Risk assessments
• Documentation and audit trails

Step 4: Stay up to date

• Sanctions lists change frequently
• Regulations evolve rapidly

Human rights sanctions are now a core compliance requirement globally. The focus has shifted from individuals to entire supply chains. While the US may currently lead in enforcement measures, the EU and other nations across the globe are rapidly catching up. Businesses must move from reactive screening to proactive risk management.

Human rights compliance is no longer just a legal obligation – it is a strategic business requirement. Companies that invest in transparency, due diligence, and monitoring will be better positioned to operate safely in an increasingly regulated global environment.