Guernica 37 Files Formal Submission to the UK Foreign, Commonwealth and Development Office

Guernica 37 Files Formal Submission to the UK Foreign, Commonwealth and Development Office for imposing Sanctions on Leading Members of the Government of Bangladesh and Members of the Notorious Rapid Action Battalion for Alleged Involvement in Human Rights Violations and Corrupt Practices

On 24 August 2021, Guernica 37 Chambers made a formal submission to the UK Foreign, Commonwealth and Development Office (FCDO) recommending sanctions for six leading members of the Government of the People’s Republic of Bangladesh and nine members of the Rapid Action Battalion for alleged involvement in human rights abuses and/or acts of corrupt practices. The Submission is made under the Global Human Rights Sanctions 2020 (Secondary Legislation laid under the Sanctions and anti-money Laundering Act 2018)

The named perpetrators are current and former senior officers within the Rapid Action Battalion (RAB), a paramilitary law enforcement and counterterrorism unit of the Bangladesh Police that is comprised of officers from both the Police and Armed Forces. As senior RAB officers, all the persons named are responsible for hundreds of extrajudicial killings, enforced disappearances, and torture.


According to U.N. bodies, human rights organisations, and survivors and victims’ families, the RAB engages in a pattern of serious human rights abuses, often targeting political opponents of the Awami League, journalists, human rights defenders, and others expressing dissent. More recently, others such as Rohingya refugees have also become targets of extrajudicial killings. Since 2015, RAB officers have committed over 440 extrajudicial killings, with dramatic increases since the “war on drugs” launched before the 2018 elections. The RAB often claims these deaths occur in “crossfire,” despite audio recordings and statements from families and witnesses that prove officers execute victims and stage the crime scenes. The RAB has also been cited for forcibly disappearing and torturing detainees, often to extract confessions.

The named officials have served as senior RAB officers during the past five years and have commanded units directly involved in serious abuses or held positions of operational control for all RAB battalions. Due to the frequency and pervasiveness of these abuses, public comments by Bangladeshi officials, and the widespread media attention they garnered, the named officials knew, or should have known, that RAB officers under their command have perpetrated serious human rights abuses. There is no evidence of credible investigations or actions taken by them to stop the abuses and ensure meaningful accountability. As such, we recommend that the U.K. government sanction these officials under the Global Human Rights Sanctions Regime under the Sanctions and Anti-Money Laundering Act 2018.

Sanctioning these RAB leaders will serve several key foreign policy priorities:

i) First, it will send a clear message to the Government of Bangladesh that the U.K. does not tolerate serious human rights abuses, even from a partner;

ii) Second, and relatedly it will assist in pressuring Bangladeshi leaders to hold perpetrators in the RAB and other agencies accountable and spur internal reform. This can prevent future attacks against the opposition and civil society and strengthen the country’s weakened democracy and commitment to the rule of law;

iii) Third, it will further U.K. regional security goals and set clear expectations for continued partnership as Bangladesh faces a generational transition of power in the coming years;

iv) These sanctions will help ensure that the UK financial system is not enabling corruption and human rights abuses, which weaken the system overall and making business riskier for UK financial institutions.


The individuals recommended for sanction in this submission are current and former commanding officers of the RAB, a paramilitary unit created in 2004 with a law enforcement and counterterrorism mandate and organised under the Bangladesh Police. Each of the perpetrators named in this submission is or has been a leader or official of a government entity that has engaged in, and whose members have engaged in, serious human rights abuses, including extrajudicial killings, enforced disappearances and torture. Furthermore, each of the perpetrators meets the standard for designation under The Global Human Rights Sanctions Regulations 2020 of being involved in activities carried out by or on behalf of a State within the territory of that State, would amount to a serious violation by that State of an individual’s: i) right to life; ii) right not to be subjected to torture or cruel, inhuman or degrading treatment or punishment; or iii) right to be free from slavery, not to be held in servitude or required to perform forced or compulsory labour.

The evidence provided in this submission confirms there is a clear, consistent pattern and practice of serious human rights abuses by the RAB. These abuses have been perpetrated since the RAB’s formation in 2004 and have worsened in the past five years, extending beyond the direct culpability of any one RAB battalion. The submission sets out details of recent individual cases of extrajudicial killings, enforced disappearances, and torture perpetrated by the RAB. These crimes have been thoroughly documented by respected local and international human rights organisations; by investigative journalists; by United Nations treat bodies, working groups, and special procedures.

Victims of serious human rights abuses at the hands of the RAB are frequently identified as opponents of Prime Minister Sheikh Hasina’s Awami League and include those affiliated with members of the political opposition, journalists, human rights defenders, and others expressing dissent. Under the leadership of the Awami League, the RAB has carried out increased attacks in the lead-up to elections, including the 2018 “war on drugs” that led to an unprecedented three-fold spike in extrajudicial killings. Such attacks are part of the Awami League’s effort to consolidate power and curtail democratic freedoms.

With few exceptions, there has been no accountability for the vast majority of perpetrators of these crimes. Government officials generally deny these crimes occur or falsely claim officers acted in self-defence, and Bangladesh’s laws and lack of an independent judiciary make it both easier for the RAB to perpetrate serious human rights abuses and nearly impossible for victims to seek redress. Efforts to encourage reform within Bangladesh have not had any demonstrable success. In fact, in recent years the rates of extrajudicial killings and enforced disappearances have dramatically escalated, and RAB leadership has been awarded with promotions, rather than punishment. For example, former RAB Director General Benazir Ahmed was promoted in 2020 to Inspector General of Police, where he has oversight for the RAB and all branches of the Bangladesh Police who have likewise perpetrated the same types of serious human rights abuses.

Such widely known serious violations of human rights could only continue unchecked for so long with the approval of officials at many levels of authority. The Submission makes clear that the RAB leadership identified for sanction knew, or should have known, that RAB officers were committing serious violations of human rights, and that they were in a position to deter and prevent such abuses and punish the subordinates who committed them. The listed perpetrators failed to take any meaningful action to prevent and stop these abuses and to provide for independent and transparent investigations with the aim of holding their subordinates accountable. For these reasons, it is recommended that these individuals included on the designated UK Sanctions List pursuant to the global human rights sanctions regime under the Sanctions and Anti-Money Laundering Act 2018. Furthermore, it is recommended that FCDO bar these individuals and their immediate families from entry into the country under Regulation 17 (Immigration) of The Global Human Rights Sanctions Regulations 2020 [2020 No. 680].


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