Sanctions against family members: a comparison of approaches between the US, UK, EU, and Australia
Anna Shpakivska, National University of Kyiv-Mohyla Academy, for Sanctions Finder
The extension of targeted sanctions to family members of primary targets is one of the most controversial trends in modern sanctions practice. Sanctioned individuals often use relatives as an instrument for asset preservation and circumvention of restrictive measures. However, the ways in which different jurisdictions respond to this challenge vary, both at the regulatory level and in law enforcement practice. This blog post examines the approaches of the US, the UK, Australia, and the European Union, based on specific case studies.
The US sanctions approach to targeting family members through sanctions
The legal mechanism of US restrictive measures is the most effective in the world, yet it remains the least consistent regarding family members of violators. The provisions of the Magnitsky Act and the Global Magnitsky Act do not provide legal grounds for sanctioning relatives. Conversely, Section 7031(c) establishes a mandatory principle: if an official is found to be involved in corruption, visa restrictions are automatically extended to immediate family members. At the same time, country-specific sanctions programs, such as those targeting Russia, Venezuela, and Iran, allow for the freezing of assets belonging to the “spouse or adult child” of a sanctioned individual. So, the legal status of family members is determined not by a unified standard, but by the specific substantive sanctions program that the competent authority decides to apply.
In December 2025, OFAC’s enforcement practice demonstrated this approach through the case of Carlos Malpica Flores, a nephew of N. Maduro’s wife who was linked to corruption within the PDVSA oil company. Within eight days, sanctions were extended to five members of his family: his mother, father, sister, wife, and daughter. The sole substantive ground for this designation was their familial relationship with the primary target. A legal challenge to such a decision within US jurisdiction is highly unlikely, as US courts limit the scope of review strictly to procedural requirements, without reviewing the merits of the decision. Consequently, an individual can be placed on the sanctions list solely on the basis of family status.
The UK sanctions approach to targeting family members through sanctions
Following Brexit, the British sanctions system obtained its own legal framework – the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). Regarding family members, the approach is inconsistent: thematic regimes concerning corruption and human rights violations do not formally provide for the automatic extension of sanctions to relatives. Yet, following the 2022 amendments, the Russian regime explicitly allows for the sanctioning of “immediate family members” of individuals “associated with” sanctioned persons, and the definition of family here is the broadest among all jurisdictions: spouse, parents, children, siblings, nephews/nieces, uncles/aunts, and grandchildren. The standard of proof is “reasonable grounds to suspect.”
March-April 2022: The United Kingdom consistently sanctioned the daughters of prominent Russian leadership figures. On March 25, sanctions were imposed on Polina Kovaleva, the stepdaughter of Foreign Minister Lavrov. The trigger was media reports about a luxurious lifestyle in London: according to government data, she owned British real estate worth approximately £4 million. The official wording in the sanctions list was succinct: “benefitting from an association with a person responsible for Russian aggression.” No unlawful activity of her own was alleged, only the fact of her familial relationship and the expensive London real estate as the material expression of this “benefit.” Shortly afterward, on April 8, sanctions were extended to two of President Putin’s daughters, Katerina Tikhonova and Maria Vorontsova, as well as Lavrov’s own daughter, Ekaterina Vinokurova. All three were subject to asset freezes and travel bans. The formal ground was identical: membership in the immediate circle of individuals responsible for the invasion and benefitting from their position. Foreign Secretary Liz Truss commented that, by freezing the assets and restricting the movement of Putin’s allies, the United Kingdom is cutting off the financial resources financing the conflict, while ensuring that those who have benefitted from Putin’s rule feel the consequences.
Australia’s sanctions approach to targeting family members through sanctions
In 2021, Australia introduced thematic sanctions programs for corruption and human rights violations, which allow for the extension of sanctions to the “immediate family members” of sanctioned individuals. The Australian definition of family is the broadest among all the jurisdictions examined: spouses, adult children and their spouses, parents, and siblings and their spouses. Regarding children, only adult children are included, as the law explicitly excludes minors.
Despite possessing the broadest regulatory toolkit, there has not been a single case of sanctions against family members in Australia. The only judicial precedent concerns the 2008 Myanmar sanctions. Zin Mon Aye, a postgraduate student at an Australian university and the daughter of a brigadier general in the Burmese junta, lost a student visa solely because the government discovered her presence in the country. She claimed she was estranged from her father and financially independent. The Federal Court dismissed her appeal. The issue was deemed non-justiciable as an exercise of the government’s foreign policy prerogatives.
The EU sanctions approach to targeting family members through sanctions
The EU’s approach was shaped through judicial practice. The 2005 Guidelines prohibited sanctioning children solely as descendants. The 2012 edition removed this restriction. Subsequently, the case law developed inconsistently: in the Tay Za case, the CJEU annulled sanctions against a businessman’s son, ruling that a familial relationship in itself does not constitute a valid ground. Conversely, in the Al-Assad case, the court upheld sanctions against President Assad’s sister, finding that, for relatives of a head of state, the connection to the regime is deemed self-evident. This contradiction has never been doctrinally resolved.
The Mazepin case demonstrates where the line is drawn. Nikita Mazepin, a Formula 1 driver and son of the Uralchem chairman, was placed on the EU sanctions list in March 2022. The ground was that his father, through the company, had financed his son’s racing career with the Haas F1 team. However, that same month, Haas terminated the contract with Nikita due to sanctions pressure, causing the economic link to vanish. The Council of the EU extended the sanctions three times, relying solely on hypotheses about his “public prominence and financial stability.” In March 2024, the court annulled the sanctions, citing a lack of evidence of an ongoing economic link. The principle was formulated clearly: an economic connection must be proven at each stage of the sanctions extension, rather than merely at the time of the initial listing.
Concluding remarks
The cases presented above demonstrate the lack of a unified approach to family-targeted sanctions across the examined jurisdictions. The US resolves this issue on a case-by-case basis, where the scope of sanctions coverage for relatives is determined not by a unified standard but by the choice of a specific program. The UK effectively recognizes “benefitting from a position” as a sufficient ground, without requiring individual proof of involvement. Australia has established the broadest regulatory toolkit, yet fails to apply it in practice. The EU has formulated the clearest standard, a proven economic link that remains relevant at every stage of the sanctions proceedings. Consequently, despite differences in legal approaches, a common feature of all the systems examined is the gap between declared standards and the actual practice of their application. It is precisely this gap that is borne by individuals whose sole ground for sanctions is their surname.
Please cite: Shpakivska, Anna, “Sanctions against Family Members: A Comparison of Approaches between the US, UK, EU, and Australia,” Sanctions Finder, June 15, 2026, https://sanctions-finder.com/insights/sanctions-against-family-members-a-comparison-of-approaches-between-the-us-uk-eu-and-australia
