Review by Appropriate Minister

The 2018 Act introduces a strictly controlled ministerial review mechanism. The Act prevents designated persons from immediately challenging section 1 regulations before the courts, by way of judicial review. Rather, they must first request either variation or revocation of the designation from the appropriate Minister (at the Treasury or Secretary of State level). Only after that initial stage may a designated person seek judicial review of a sanctions-related decision; see Chapter 9 of this Guide. Thus, those who are subject to financial sanctions can challenge their listing, but financial sanctions will remain in place while the challenge or request is being considered.