UK Magnitsky sanctions & the Sri Lankan record

§1 What the regime is

The Global Human Rights Sanctions Regulations 2020 (commonly called the UK Magnitsky regime) were made under the Sanctions and Anti-Money Laundering Act 2018. They give the Foreign Secretary power to designate individuals and entities the FCDO assesses to have been involved in, or to have facilitated, serious violations of the right to life, the prohibition on torture or cruel/inhuman/ degrading treatment, or the prohibition on slavery, servitude, and forced labour. In 2021 the regime was widened by the Global Anti-Corruption Sanctions Regulations to cover serious corruption.

A designation produces an asset freeze in the UK financial system, a travel ban into the UK, and prohibitions on specified UK-related dealings. The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, maintains the UK Consolidated List of every designated person across UK sanctions regimes and issues operating guidance to UK firms. The National Crime Agency runs the criminal enforcement side and operates the Unexplained Wealth Order regime. The Serious Fraud Office handles overseas-bribery and serious-fraud casework that touches UK jurisdiction.

None of these bodies are TLTE. All are referenced in the standing /laws index and in Civic Repair · Pillar 08.

§2 The designation pathway

The FCDO has published a policy note describing how it considers designations. In outline: the FCDO collects open-source evidence, intelligence assessments, and submissions from civil-society bodies; it tests the case against the regime's evidentiary threshold (a reasonable-grounds-to-suspect standard, with detailed internal procedure); it considers the foreign-policy purpose, and it applies procedural safeguards, including the right of a designated person to seek review. The Foreign Secretary makes the final decision.

Civil-society submissions do not create designations. They feed an internal FCDO process. Submissions are most useful when they are (a) tightly cited to mandated-body sources, (b) framed in the regime's own statutory language, and (c) routed through accredited bodies (Redress publishes a standard NGO guide; the All-Party Parliamentary Human Rights Group and other parliamentary channels can carry weight).

§3 Where the Sri Lankan record sits

The open evidentiary record on the final phase of the armed conflict and its long aftermath is held by mandated bodies, not by TLTE. The UN Panel of Experts (2011), the OHCHR Investigation on Sri Lanka (OISL, 2015), successive Human Rights Council resolutions culminating in A/HRC/46/20, and the OHCHR-mandated Sri Lanka Accountability Project all sit at Tier A. ITJP, PEARL, Amnesty, Human Rights Watch, and the International Crisis Group sit at Tier B. PTA-related impunity, conflict-related sexual violence, and enforced-disappearance patterns are documented across these bodies; their counts and named-incident files belong to them.

What this means in Magnitsky terms: the regime's threshold is set by the FCDO, not by TLTE; the case for any specific designation is a matter for accredited submitters working from the Tier-A and Tier-B record; and TLTE's role is structural — to say that the UK already has the legal architecture, that its existing thresholds should be applied consistently, and that a published, reasoned decision either way is a legitimate civic-repair outcome.

§4 How the archive supports submissions made by others

Every load-bearing claim in this archive is anchored to a citation in the Citations Registry and surfaces through the Evidence Matrix. Accredited bodies preparing submissions can use the archive in three ways:

• ◇As a citation index. The archive maps Tier-A and Tier-B sources to specific structural questions (PTA, disappearances, militarised checkpoints, eastern factional history). It is not the evidence; it is a path back to the evidence held by mandated bodies.
• ◇As a structural framing. Pages such as /case/falsifiability and /case/civic-repair/precedent-and-pathway translate the open record into language a parliamentary or FCDO audience can read.
• ◇As a continuity record. The archive's append-only changelog and continuity protocol mean a citation linked today is verifiable tomorrow — useful when a submission may be revisited months later.

§5 A note on named figures and the eastern split

Public search interest in named former eastern commanders and paramilitary figures is high. Most of that interest is best served by Tamil Guardian, ITJP, PEARL, OHCHR, and ICG, all of which carry named-individual material under their own mandates. The single place on this archive where a Tier-A naming exception is canonical — for the Karuna split and its post-2004 trajectory — is the attribution dossier and the Eastern Command pages. Even there, the framing is structural attribution (who did what, with what evidence, under what command), not target-listing.

• ◇Eastern Command — Karuna / TMVP trajectory
• ◇Civic Repair · Pillar 08 · Accountability
• ◇LTTE Era — Unfinished Ledger