Disrupting State Capture: The UK Needs to Develop a More Targeted Sanctions Strategy for Georgia

Photo credit: Creative Commons

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As protests continue in Georgia, with calls for new elections, and the release of political prisoners, the UK government has announced sanctions against six Georgian individuals, bringing the total number of Georgians sanctioned to eleven. According to the Foreign Office (FCDO), this crackdown is part of the Foreign Secretary’s campaign to tackle corruption and dirty money, as well as those who ‘undermine democracy and the rule of law.' ILP welcomes the UK government’s actions but encourages a much more focused and ambitious use of sanctions to prevent the capture of the Georgian state that is currently underway by the Georgian Dream ruling party.

Of those individuals sanctioned, only two of the eleven were designated via the UK’s Global Anti-Corruption regime. These were Mikheil Chinchaladze, Chairman of the Tbilisi Court of Appeal, and Levan Murusidze, a Member of the High Council of Justice of Georgia, who are also the leaders of Georgia’s ‘Judicial Clan’, a group of judges undermining the rule of law for the benefit of the Georgian Dream party and to increase their control over the judicial system. Both are foreign public officials performing a judicial function, deemed to be involved in serious corruption by ensuring that judicial appointments and decisions favour the incumbent Georgian Dream Party, according to the FCDO press release. Both judges had already been sanctioned by the United States, a year earlier.

The UK government’s use of its Global Human Rights sanctions regime rather than the Global Anti-Corruption regime for Georgia is notable. Human rights abusers are more likely to be middle to senior level technocrats, as opposed to the powerful figures heading up a kleptocracy, which enables and facilitates such acts. None of those sanctioned by the UK to date are the political, financial or media disinformation leaders of Georgia’s state capture.

Georgia held Parliamentary elections in October 2024, during which international election monitors and civil society reported serious and widespread incidents of voter intimidation, attacks, human rights abuses, and other serious irregularities. The key figures responsible for state capture and corruption in Georgia, as well as the hijacking of elections and state institutions, have significant business, media, and financial links to the UK. Sometimes the imposition of targeted sanctions is merely symbolic, but in the case of Georgia, imposing sanctions on key kleptocrats would have a significant deterrent effect and a profound impact on the country’s geopolitical course, which has recently veered violently towards mirroring President Putin’s Russia. The United States and Ukraine have been much more comprehensive, strategic, and ambitious in their use of sanctions to target the political and media disinformation leaders by sanctioning, amongst others, Bidzina Ivanishvili, the leading figure orchestrating the state capture of Georgia, as well as his closest allies and family members.    

Photo credit: Creative Commons

What are sanctions?

Since 2021, the UK government has operated a Global Anti-Corruption Sanctions regime, which complements its Global Human Rights Sanctions regime (introduced in 2020). Both regimes are underpinned by the Sanctions and Anti-Money Laundering Act 2018, which gives the UK government wide powers to develop and implement sanctions regimes to achieve a range of goals, from compliance with UN and international obligations, to the promotion of its foreign policy objectives, respect for democracy, the rule of law and good governance. 

Targeted sanctions are a foreign policy tool that are used to target individuals and entities involved in illicit conduct including serious corruption, human rights violations, and the degrading of the rule of law. A sanctions designation leads to serious consequences including the freezing of assets, curtailment of travel, visa withdrawal, disqualification from being a company director, as well as effective disbarment from access to professional and financial services within the sanctioning authorities’ jurisdiction. According to ILP research, a public designation of sanctions often leads to targets being ostracised from the business and elite social networks they rely on. Importantly, our research has established that a designation and the additional international media and political attention it brings can provide an effective shield against extreme harassment for in-country media and activists reporting on a target’s activities (see also this recent analysis article by the Law Society Journal).

Considering sanctions as part of a holistic legal strategy campaign can be an effective way for civil society to pursue accountability for corruption. The evidence threshold required to achieve a sanctions designation is considerably lower than a criminal conviction; moreover, sanctions designations are often issued in a shorter timeframe than criminal convictions and achieve immediate impact. Importantly, a sanctions designation doesn’t nullify the pursuit of a criminal conviction: in fact, designations assist in the pursuit of a criminal conviction, by freezing the target’s assets so that they can’t be removed from the jurisdiction, as well as bringing much needed publicity to a case.

Using Targeted Sanctions to Counter the Threat of Russian disinformation in Emerging Post-Soviet States

On the day the first tranche of Geogia sanctions were announced by the UK government, Salome Zourabichvili, the Fifth President of Georgia, gave evidence to the UK Foreign Affairs Committee on the threat that disinformation poses to democracies worldwide and specifically disinformation in the context of Russian interference and the disputed October 2024 Georgian election. Zourabichvili gave evidence to Parliament on reports of hybrid warfare by Russia in Georgia and the propagation of anti-Western narratives. In her testimony, Zourabichvili highlighted that currently in Georgia, ‘every day brings new repressive laws’, citing the restrictive media and civil society legislation passed in parliament that same day, noting that ‘practically everybody is in one way or another under the repressive laws’. This points to a worrying trend that Georgia continues to move closer to Putin’s Russia and away from liberal, democratic values.

Zourabichvili compared Georgian Dream’s recent actions to those of Russia’s in terms of its own suppression of civil society, with the difference being that in Georgia, the process ‘is going extremely fast.’ ‘We do not have a justice system anymore in Georgia,’ Zourabichvili said, after stating that out of 400 people detained as part of the ongoing protests, 50 still remain in prison. She also gave testimony related to the disappearances of civil society activists who ‘reappear in some police station’ and the treatment of prisoners in custody, including most recently of opposition politician Elene Khoshtaria, who accused police of assaulting her before stripping her naked. In all cases, Zourabichvili again noted the similarities to the ‘Russian method.’ Zourabichvili emphasised that a characteristic of Georgia’s civil society throughout the decades has been its resilience, and that there still exists a ‘very vivid’ Georgian civil society that is resisting the government oppression.

Zourabichvili stressed that Georgia is currently at risk of becoming a grey zone, where those sanctioned by the UK for example can find the freedom to operate. Citing Georgia’s offshore law, which allows taxes and duties to be exempted on offshore assets being brought into the country, Zourabichvili claimed that any potentially sanctioned oligarch could make use of this loophole by becoming a Georgian citizen. In addition, she noted that Georgian citizens are not considered to be under sanctions by Georgian banks if proof has not been substantiated by the Georgian courts, again creating the possibility for anyone friendly to the Georgian government to bypass Western sanctions if they are granted Georgian citizenship by the new president, Mikheil Kavelashvili, whose election is disputed.

Zourabichvili informed the Committee that the 2024 parliamentary elections in Georgia were a ‘large, sophisticated, manipulation operation’ that was ‘inspired and supported by Russians and Russian methods’. Asked by the Parliamentary Committee whether the West had done enough to counter pro-Russian narratives and whether the UK should sanction the pro-government television station Imedi — often a Georgian Dream propaganda outlet - Zourabichvili told the MPs that ‘I think you know what you should do’, noting that the UK's sanctions policy should focus more on changing behaviour, rather than just sanctions as a form of punishment. 'The more people realise that something is happening, the sooner we will see a real strategy', she said.

UK versus US sanctions strategy

Of the eleven Georgians sanctions by the UK government, five of these individuals were previously sanctioned by the US. Although these UK sanctions were achieved through a combination of using the human rights as well as anti-corruption legal frameworks, all of these designations are in the context of the violence and repression of civil society and the rule of law. None of those sanctioned by the UK to date are the political, financial or media disinformation leaders of Georgia’s state capture. In order to more effectively challenge the dismantlement of the Georgian state, the UK needs to target the oligarchs close to President Putin who are orchestrating this.

List of individuals sanctioned by the UK following US sanctions action

Name	Role	Conduct Leading to Designation (source FCDO press releases)
Vakhtang Gomelauri	Minister of Internal Affairs	Responsible for activity amounting to a serious violation of the right not to be subjected to cruel, inhuman, or degrading treatment. During protests after the suspension of EU accession talks, the Ministry of Internal Affairs oversaw police violence against protestors.
Zviad Kharazishvili	Director of the Special Tasks Department	Responsible for activity amounting to a serious violation of the right not to be subjected to cruel, inhuman, or degrading treatment. As Chief of the Special Task Department, oversaw violent targeting of citizens, opposition, journalists, and activists after protests over the foreign influence law.
Mileri Lagazauri	Deputy Director of Special Task Department	Responsible for activity amounting to a serious violation of the right not to be subjected to cruel, inhuman, or degrading treatment. As Deputy Chief of the Special Task Department, oversaw violent targeting of citizens, opposition, journalists, and activists after protests over the foreign influence law.
Mikheil Chinchaladze	Judge	Abused position as a member of Georgia’s High Council of Justice, undermining the rule of law and the public’s faith in Georgia’s judicial system.
Levan Murusidze	Judge	Abused position as a member of Georgia’s High Council of Justice, undermining the rule of law and the public’s faith in Georgia’s judicial system.

In contrast to the UK, the US has also sanctioned Bidzina Ivanishvili, the country’s richest, most powerful oligarch, and founder of the ruling Georgian Dream political party, for eroding democratic institutions, enabling human rights abuses, and leaving Georgia vulnerable to continuing occupation by Russia of more than 20 percent of its territory.

The US has also used its sanctions regime to target those who use the media to spread disinformation in Georgia (see table below), yet the UK has taken no such action. The UK’s sanctions strategy should have a greater focus on those spreading disinformation and propaganda in support of the current regime, such as Irakli Rukhadze, a business partner of Ivanishvili and owner of Imedi TV, which is owned and operated out of London.

Media and disinformation figures designated by US sanctions

Name	Role	Legal Basis	Conduct Leading to Designation according to US State Department press releases
Konstantine Morgoshia	Founder of Alt-Info, a media company	Executive Order (E.O.) 13818	Used media company to amplify disinformation and spread hate speech and threats against marginalised communities. In July 2021 and 2023 he advocated for violent attacks against marginalised persons peacefully exercising their fundamental freedoms of expression and assembly and led hundreds of followers to break into non-governmental organisation offices and attack journalists and police officers at the scene.
Zurab Makharadze	Media personality associated with Alt-Info	Executive Order (E.O.) 13818	One of the most vocal supporters of violence against peaceful demonstrators and marginalised Georgians. He directly encouraged violence against minority groups and journalists online prior to the violent attacks on marginalised communities and helped to direct, organise, and fundraise for the anti-human rights violence in 2021 and 2023. During the attacks, he led a group to clear out protestors from in front of the Georgian parliament and then instructed followers to go with Morgoshia to attack the non-governmental organization offices.

The imposition of UK sanctions against senior judges is an important act to safeguard the rule of law in Georgia. However, the US has gone further by imposing sanctions against additional senior judges and officials, such as senior prosecutors, including:

Judges and Prosecutors sanctioned by US

Name	Role	Legal Basis	Conduct Leading to Designation
Mirza Kezevadze	Deputy Director of Special Task Department	Executive Order (E.O.) 13818	Brutality Against Protesters, Journalists, and Politicians
Irakli Shengelia	Judge	Section 7031(c) visa restriction	As above
Valerian Tsertsvadze	Former Judge	Section 7031(c) visa restriction	As above
Otar Romanov-Partskhaladze	Former Chief Prosecutor	Executive Order 14024.	Operating or having operated in the management consulting sector of the Russian Federation economy

The UK’s sanctions strategy should prioritise and focus on the leading kleptocrats in politics, finance and media who are leading the organised state capture of Georgia.

ILP’s Support to Georgian Civic Space

Many of those sanctioned have been responsible for the violent repression of protests against the introduction of the ‘Transparency of Foreign Influence’ law. In the months leading up to Georgia’s 2024 Parliamentary Elections, the ruling party, Georgian Dream, attempted to re-introduce a law that sought to censor, fine, and shut down civil society, media, and election monitoring organisations. The Transparency of Foreign Influence law would also force civil society and media organisations to disclose detailed personal information on employees, including sexual orientation, political views, and trade union membership. The Foreign Influence law - modelled on parallel Russian ‘Foreign Agents’ legislation which has forced Russian civil society and media to relocate outside of the country - sparked the largest mass protests seen in Georgia’s history. Despite a veto from President, Salome Zourabichvili, who denounced it as ‘Russian in spirit and essence’, the ruling party used its parliamentary majority to enact the law, making it almost impossible for Georgian civil society to operate and  creating an immediate block to the country’s future EU accession, a goal enshrined in Georgia’s Constitution and supported by 80 per cent of the population. Critics of the law describe developments in Georgia as an attempt by Russia to bring its neighbouring country back within its sphere of influence. In October 2024, Georgian Dream announced it had won a parliamentary majority in the Georgian elections, a result that has been widely rejected internationally, including by the European Parliament and the United States.

ILP’s legal experts supported a coalition of 121 civil society and media organisations, opposition MPs and President Zourabichvili, to file both a case challenging the law in the Georgian Constitutional Court and, when this was unsuccessful, to lodge a case before the European Court of Human Rights, alleging violations of the rights to freedom of assembly and association, freedom of expression, privacy and non-discrimination, and that the law places undue restrictions on fundamental rights. A few days later, the European Court ruled against Russia’s similarly drafted 'Foreign Agents' Law, finding it to be a violation of the European Convention and ordering Russia to pay compensation. The Court also found that the law 'contributed to shrinking democratic space by creating an environment of suspicion and mistrust...and forced self-stigmatization while severely limiting the ability of ...media...and journalists to participate in public discourse and carry out their professional duties.' ILP is continuing its legal support to defend Georgian civic space and anti-corruption monitoring, including through the compilation and submission of confidential sanctions dossiers to the UK government on behalf of Georgian civil society.

In conclusion, while the UK government’s sanctions against Georgian individuals, particularly those involved in corruption and the erosion of democracy, are a welcome step, they are insufficient in addressing the broader threat posed by the capture of the Georgian state. The UK's focus on senior-level figures within the judiciary and human rights violators, while important, misses the key oligarchs and media moguls orchestrating the country’s slide toward authoritarianism and its increasing alignment with Russia. Countries such as the United States and Ukraine have demonstrated a more ambitious, comprehensive approach, targeting key figures like Bidzina Ivanishvili, whose influence in politics, business, and media continues to drive the state's capture as well as his allies responsible for disinformation campaigns and media manipulation. For the UK’s sanctions to have a more significant and lasting impact, they must be expanded to include the small circle of political and media elites funding and facilitating the Georgian Dream party, with the goal of reversing the ongoing state capture and safeguarding Georgia’s democratic future. Through more strategic, ambitious, and robust sanctions, the UK can better contribute to countering corruption and disinformation, ultimately helping to dismantle entrenched networks of corruption and encourage Georgia’s leadership back towards democratic values, to prevent further alignment with Russia.