Global Human Rights and International Humanitarian Law Sanctions Regulations 2026

Lord Frost Excerpts

Wednesday 4th November 2026 Lords Chamber

[Lord Frost (Non-Afl)]

My Lords, I support the regret amendment from the noble Lord, Lord Leigh of Hurley, and draw attention to my entry in the register of interests.

I will raise briefly two specific concerns on this proposed legislation. The first is the risk that the sanctions under consideration will not be effectively targeted. The noble Lord, Lord Leigh, talked about the chilling effect, as I think one could describe it, of the ambiguity of aspects of these sanctions and definitions. That is a negative risk, if you like. However, the Foreign Secretary in the Commons, when announcing these sanctions, also set out a positive duty. He said that

“we will absolutely ensure that it does not hit green-line Israel”.—[Official Report, Commons, 8/9/26; col. 887.]

He also said:

“We will continue to support important and valued trade with green-line Israel”.—[Official Report, Commons, 8/9/26; col. 882.]


If those were not just words, they imply a positive duty to act, by embassies, government officials and departments that support trade between the UK and Israel. Businesses need to know what positive, practical support the Government can still give, and government officials need to know what they can and cannot do under these sanctions. Can the Minister explain what the Government will do to deliver on the Foreign Secretary’s positive commitment? Will they publish guidance, for example to make clear what trade and investment is supported by HMG and their officials, and what is not? That is my first concern.

The second is how the follow-up regulations to these sanctions are to be handled in practice. They are presented as the first stage in a series of measures tightening restrictions over time, and the Government’s planned measures to prohibit or restrict import services advertising will be very far-reaching. They will hit a lot of people who probably never imagined they were going to be hit by this. There is a high risk of getting the detail wrong or having inadvertent consequential effects.

This does happen. Some of us may remember that the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023 banned legal advisory services. They were made on 27 June that year and came into force three days later. It took an outside stakeholder, a law firm, to tell us, the legislators, that these regulations actually made it a crime for UK-based lawyers to advise on how to comply with the sanctions. The firm went on to say that this was “unnecessary, and likely unintended”. Your Lordships’ Secondary Legislation Scrutiny Committee went on to confirm this was the effect and it took the Government a year to get the legislation right.

This happened in a sanctions regime that by then was well understood and often used, so will the Government commit to doing the maximum to avoid a similar situation arising again? Instead of drafting follow-up laws and simply bringing them into force, will they commit to ensuring that measures under this legislation will be published in draft, consulted on and properly debated in this Parliament first?