As the UK government prepares to announce a ban on trade with Israel’s settlements, Amnesty International UK is setting out the tests any ban must pass – and making clear that the strength of the policy will lie in its scope and implementation.

In July, then-Trade Minister Sir Chris Bryant confirmed the government was “actively working on a plan to bring forward a comprehensive ban.” In August, Foreign Secretary Ed Miliband confirmed the government’s intention to “target sanctions at those who participate in illegal settlement expansion.” Amnesty International UK welcomes the direction of travel and the commitment to act – and is today setting out what a comprehensive and enforceable ban must look like in practice.

Peter Frankental, Amnesty International UK’s Economic Affairs Director, said:

“Palestinians in the occupied West Bank are living through a campaign of ethnic cleansing. Settlements are at the heart of Israel’s illegal occupation and system of apartheid – and the trade that sustains them must be stopped. The UK has a legal responsibility to act.

“An end to trade which benefits settlements is long overdue, and we welcome the government’s commitment to act. But the devil will be in the detail. A ban that covers only goods or only imports, leaves services and investment untouched, or lacks real enforcement powers will fall short of the comprehensive prohibition that international law demands and that is needed to hold Israel accountable.

“We will be looking carefully at every line of what is published. We want this to work – and we will be clear about where it needs to go further.”

What an effective ban looks like

A comprehensive ban must cover goods, services and investments – and must be backed by strong enforcement mechanisms and compliance incentives. Amnesty will be examining whether any ban is comprehensive in scope, contains robust definitions and is clear in its direction to business. Any UK measures must be defined by reference to international law, cover all trade activity which benefits settlements and include real enforcement powers.

These are the three criteria Amnesty will be applying.

Scope: goods, services and investments

A ban limited to imported goods alone will not be sufficient. Amnesty will be looking for a ban that covers:

Goods: including products wholly or partly produced in settlements, and goods incorporating settlement-grown or settlement-manufactured inputs even where final processing occurs within Israel. A ban that can be circumvented by blending settlement produce with Israeli produce before export is not a ban.Services: the settlement economy depends on services provided by companies based in the UK, Israel and internationally. A comprehensive ban must prohibit UK companies from providing any services including financial services, construction, insurance, logistics, security, legal services, and marketing that facilitates, supports or economically benefits settlement activity. This must include the advertising and letting of settlement properties – the marketing of settlement properties at events such as the Great Israeli Real Estate event held in London is precisely the kind of activity a comprehensive ban must prohibit, as must the listing of settlement accommodation on platforms such as Airbnb and Booking.com.Investments: the ban should prohibit investment in settlement businesses and the donation of charitable funds to further settlement activity.Territorial scope: the ban must cover all Israeli settlements in the occupied West Bank, including East Jerusalem, consistent with the UK’s longstanding position that they are illegal under international law. It must include explicit protections to ensure that Palestinian producers in occupied territory are not inadvertently penalised – with State of Palestine certification used to verify the origin of Palestinian goods, mirroring the mechanism already used for Ukrainian producers in Russian-occupied territory.Real enforcement powers

Amnesty will be looking to see that:

The Office of Financial Sanctions Implementation (OFSI) is given responsibility for financial sanctions, including restrictions on finance and insurance that benefit settlement activityThe Office for Trade Sanctions Implementation (OTSI) is given responsibility for non-financial servicesBoth bodies have similar civil and criminal enforcement powers – including strict-liability monetary penalties – that have been used to enforce sanctions against Russia since 2022In addition to providing OFSI and OTSI with relevant powers, HMRC, Defra, the Financial Conduct Authority and the Pensions Regulator are given relevant enforcement powers, and the regulations expressly provide for effective cooperation and information sharing where jurisdictions overlap.The Notice to Importers for Israeli goods is updated with stronger guidance on steps to take to ensure and clear criminal and civil consequences for non-complianceEnforcement powers apply to the whole UK supply chain, including distributors, wholesalers and supermarketsGuidance for business

The government should issue clear, sector-specific guidance for UK importers, distributors, retailers and service providers – including specific guidance on supply chain due diligence and contracts.

A detailed set of benchmarks setting out Amnesty’s full assessment criteria is available here.

The international context

The UK is not acting in a vacuum. Spain has already implemented a ban on settlement goods and the advertising of settlement services; the Netherlands’ ban comes into force on 21 September; Ireland passed legislation banning settlement imports in July; and Belgium’s ban came into force the same month. Norway has published draft legislation covering imports, exports and services for public consultation. The EU is discussing a bloc-wide ban.

Nor does the UK need to start from scratch. Since Russia’s full-scale invasion of Ukraine, the UK has enforced complex trade sanctions distinguishing between goods originating in occupied Ukrainian territory and those originating in Russia itself. The same framework, and the same enforcement bodies, can be applied here.

The UK’s ban must be at least as comprehensive as those already in force among its European partners but must go further, particularly on services and investment which play a key role in the maintenance and expansion of Israel’s settlements.

The legal obligation

The International Court of Justice, in its landmark advisory opinion of July 2024, confirmed that states – including the UK – must take steps to prevent trade or investment relations that assist in the maintenance of Israel’s illegal occupation of the Occupied Palestinian Territory. The UK is a signatory to the Geneva Conventions, which under Common Article 1 binds all third-party states to “ensure respect” for international humanitarian law under all circumstances. This means the UK should not take actions that reinforce the illegality of Israel’s appropriation of Palestinian land and resources, and the transference of its own population into the territory it occupies.

A ban on settlement goods is not the end of the road but an essential step towards meaningful compliance with the UK’s obligations under international law. To further meet those obligations, the government must end all trade and cooperation that contributes to the ongoing genocide in Gaza, the ethnic cleansing of Palestinians in the West Bank, the system of apartheid that Israel imposes on Palestinians and its unlawful occupation.

The ban is not a foreign policy preference. It is a legal obligation – and Amnesty International UK will assess any measures against that standard.