Foreign, Commonwealth and Development Office

The complainant has requested information about coordination with Jersey relating to asset freezing under the Russia sanctions regime in respect of two named individuals. The Foreign Commonwealth and Development Office (FCDO) made a partial disclosure but refused to provide the remainder citing section 27(1)(a), (c) and (d) (international relations), section 31(1)(a) (law enforcement), and section 40(2)(3A)(a) (personal data). After a considerably delayed internal review which followed the Commissioner’s intervention, FCDO made a further partial disclosure. It introduced reliance on section 27(2) and refused to confirm or deny whether all the above information caught by these exemptions represents all the information held that would meet the terms of the complainant’s request. It cited section 23(5) (security bodies) and section 24(2) (national security) as its basis for refusing to confirm or deny if further information is held. During the course of the Commissioner’s investigation, it introduced section 23(1) and section 24(1) in the alternative in respect of some of the information that it had already confirmed it held. The Commissioner’s decision is that FCDO is entitled to rely on section 23(1) or section 24(1) in the alternative, section 27(1)(a), (c), (d) and (2), section 31(1)(a) and section 40(2)(3A) as its basis for withholding information it holds within the scope of the request. It is also entitled to refuse to confirm or deny whether it holds other further information within the scope of the request on the basis of section 23(5) and section 24(2).