I thank both noble Lords for their questions and their support for this measure. I want to address the important issues that they raised.
The noble Lord, Lord Purvis, asked about the judiciary. He is absolutely right that the judiciary in Iran is not independent. It is an agent of the state and its members are part of the architecture of that state, which has caused some of the grossest human rights
abuses. They are available to be sanctioned. We have sanctioned members of that judiciary and will continue to do so as and when we get evidence to support doing that. He also asked about safe and legal routes. We are always looking at this issue. It is obviously a responsibility of the Home Office, with which we work closely; we also work internationally to make sure that safe and legal routes exist. I am very happy to give the noble Lord a more detailed briefing on that.
The noble Lord is absolutely right about the proxies and other states, individuals and companies through which the Iranian Government operate. We work with the EU, as well as with our partners in the US, Canada and many other countries, to try to ensure that a comprehensive regime exists. The Secretary of State can take urgent action under our sanctions regime to replicate sanctions that are implemented by the US and Canada. We will certainly take that action as soon as it is required, and can do so at great speed. Very often, the information comes out in relation to a particular incident or individual, and sometimes that requires speedy action. The Foreign Secretary and the Government are happy to move quickly on that and keep noble Lords informed about what we are doing.
The issue of facilitators is perhaps more relevant to the next SI but it is absolutely right that the noble Lord raised it. Unlike Iran, we are a free country with independent institutions, such as the judiciary. However despicable an individual’s acts, whether the crime is a murder or whether, in a case such as this, an individual feels that they have been wrongly sanctioned, they must have the ability to be supported by the legal system. No one argues with that; where we have a problem is with some people who have made a lot of money out of dirty money coming into the UK. We want to ensure that they are given the full glare of publicity and are understood to have been part of the problem.
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The noble Lord, Lord Purvis, rightly talked about malicious legal cases, which can have a huge impact on the taxpayer and delay the system under which we have operated, particularly on asset freezes. This can be more complicated if a country such as Iran is using proxy organisations, of course, but we remain absolutely determined to shine a light on any state or individual actor being used by Iran to avoid sanctions. We will make sure that those matters are kept under constant review.
I note the noble Lord’s point about shipping. He is absolutely right that there is no point in denying a ship access to our waters and ports if they can just go to a near neighbour. That is why we work extremely closely with the International Maritime Organization and others to try to make sure that we have a universal system that is accepted across the world.
We have sanctioned more than 400 Iranian individuals and entities, including the IRGC in its entirety, in response to the regime’s human rights violations, nuclear escalation and terrorism. Since the protests began in October, we have sanctioned 204 individuals and entities, including 54 linked to the IRGC. Our sanctions against Iran account for a significant proportion of our sanctions work across the department.
The noble Lord, Lord Collins, talked about broader co-operation. This is a matter of great priority for the G7, which is doing great work in looking at asset seizures and making sure that we have both a comprehensive regime across our allies and actions that work in lockstep with those countries.
It has rightly been said that all areas of responsibility of the British Government must be part of this. The UK sanctions regime applies in all UK overseas territories and Crown dependencies, either by Orders in Council or through each jurisdiction’s own legislation. The United Kingdom, the Crown dependencies and the overseas territories stand united in condemning the Russian Government’s aggression and the behaviour of the Iranian Government, and are working in lockstep with us to enforce UK sanctions, including freezing over $9 billion of assets. Each territory’s Government are responsible for the implementation and enforcement of sanctions within their territory. We and the Office of Financial Sanctions Implementation provide technical support through the targeted use of EDI funds to build capacity and strengthen sanctions enforcement with other restrictions.
Both noble Lords talked about how we are judging and reviewing this mechanism and making sure that we are creating a transparent system that holds us to account. The creation of the Office of Trade Sanctions Implementation was announced on 11 December. This new unit will strengthen the implementation and enforcement of our trade sanctions and ensure that UK sanctions are as impactful as possible. We will also legislate to give the OTSI a toolkit of civil enforcement powers, including the ability to levy civil monetary penalties, similar to the powers of the Office of Financial Sanctions Implementation. These new civil enforcement powers will complement HMRC’s existing criminal enforcement powers in relation to trade sanctions. The OTSI will become fully operational this year, once it has its new legal powers, and more information on timing will be available in due course.
We have listened closely to the concerns of industry, particularly in the light of Ukraine. We want to support and foster better understanding and compliance with the UK’s trade sanctions. I think that covers most of the questions.