Foreign, Commonwealth and Development Office

The complainant has requested information about asset freezing proposals made by Jersey to the UK under the Russia sanctions regime. The Foreign, Commonwealth and Development Office (“FCDO”) explained that the information formed part of the information described in an earlier request made by the complainant. After internal review, it explained that the information it held within the scope of the request (which was not previously disclosed to the complainant) was exempt under section 27(1)(a), (c) and (d) and section 27(2) (international relations), section 31(1)(a) (law enforcement), and section 40(2)(3A) (personal data). It also 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 doing so. 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 the position taken. The Commissioner does not require further steps.