UK sanctions

Guide

Last updated 7 January 2021

The UK’s sanctions framework changed on 1 January 2021. This page tells you about UK sanctions that are now in force.

Overview of UK sanctions

Sanctions are measures that the UK puts in place to fulfil a range of purposes. These include complying with UN and other international obligations, supporting foreign policy and national security objectives, as well as maintaining international peace and security, and preventing terrorism.

The UK implements a range of sanctions regimes through regulations made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). The Sanctions Act provides the main legal basis for the UK to impose, update and lift sanctions.

UK sanctions Regulations made under the Sanctions Act apply in the whole of the UK, including in Northern Ireland. The prohibitions and requirements in these Regulations apply to conduct by UK persons. This includes anyone in the UK (including its territorial waters), UK nationals outside of the UK, and bodies incorporated or constituted under the law of any part of the UK. It is government policy for UK sanctions measures to be given effect in the British Overseas Territories and Crown Dependencies to make sanctions as effective as possible.

Some sanctions measures apply through other legislation, such as the Immigration Act 1971 and the Export Control Order 2008.

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Types of sanctions

The UK may impose the following types of sanctions measures:

  • trade sanctions, including arms embargoes and other trade restrictions
  • financial sanctions, including asset freezes
  • immigration sanctions, known as travel bans
  • aircraft and shipping sanctions, including de-registering or controlling the movement of aircraft and ships

Some sanctions measures (such as asset freezes and travel bans) apply only to persons or ships which have been designated or specified by the UK Government. This is publicised through the UK sanctions list, which contains designations or specifications made using legislation under the Sanctions Act.

The Office of Financial Sanctions Implementation in HM Treasury also maintain a sanctions list called the Consolidated List of Asset Freeze Targets, which contains details of designations where asset freeze measures apply.

Trade sanctions

The Department for International Trade (DIT) implements trade sanctions.

Trade sanctions can include prohibitions on:

  • the import, export, transfer, movement, making available or acquisition of goods and technology
  • the provision or procurement of services related to goods and technology
  • the provision or procurement of certain other non-financial services

DIT’s Export Control Joint Unit administers the UK’s system of export controls and licensing in relation to trade sanctions. DIT’s Import Licensing Branch implements trade sanctions relating to imports.

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Financial sanctions

HM Treasury implements and enforces financial sanctions. The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK.

Financial sanctions include restrictions on designated persons, such as freezing their financial assets, as well as wider restrictions on investment and financial services.

OFSI helps companies understand their financial sanctions obligations, monitors compliance and assesses suspected breaches. OFSI can also issue licences to allow otherwise prohibited financial transactions to take place under certain circumstances.

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Transport sanctions

The Department for Transport implements and enforces sanctions in the aviation and maritime sectors.

Transport sanctions include restrictions on the ownership, registration or movement of ships and aircraft. This can include restrictions on movements to and from ports, harbours and airports, and the detention of ships and aircraft.

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Immigration sanctions

The Home Office implements and enforces immigration sanctions, also known as travel bans. Those subject to travel bans will be refused leave to enter or remain in the UK. Any applications they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.

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Exceptions and licensing

Exceptions

Sanctions Regulations set out exceptions to some of the sanctions prohibitions which apply within certain defined circumstances. An exception applies automatically, and you do not need to obtain a licence under sanctions legislation. If you are unsure whether an exception applies in your circumstances, you should seek independent legal advice.

Licensing for trade sanctions

Licences may be issued for certain activities that trade sanctions measures would otherwise prohibit. The tables in Section 3 of each of the statutory guidance documents for the relevant sanctions regulations set out the grounds for granting trade sanctions licences.

If your activity relates to import sanctions measures, you can apply for an import licence from DIT’s Import Licensing Branch. You can make a licence application using their online import licensing system ICMS.

If your activity relates to any other trade sanctions measures, you can apply to DIT’s Export Control Joint Unit. You can make licence applications related to military and dual use items through their online export licensing system SPIRE. To make licence applications for other items/services email tradesanctions@trade.gov.uk.

Licensing for financial sanctions

Licences may be issued for certain activities that financial sanctions measures would otherwise prohibit. The ‘Treasury Licences’ schedule to the relevant sanctions regulations sets out the purposes under which certain individual financial sanctions licences may be granted.

If your activity relates to financial sanctions measures, you can apply for a licence from the Office of Financial Sanctions Implementation in HM Treasury. Find out if you need a financial sanctions licence and how to apply.

Licensing for transport sanctions

Licences may be issued for certain activities that transport sanctions measures would otherwise prohibit. If your activity relates to transport sanctions measures, you can apply for a licence from the Department for Transport.

Exceptions for immigration sanctions

In certain circumstances exceptions may be made to an immigration sanction to allow travel to or through the UK which would otherwise be prohibited. If you are the subject of an immigration sanction you can make a request to travel in exceptional circumstances using the visa application process.

Activity prohibited by multiple measures

There may be situations where activity would be prohibited by more than one type of sanctions measure (for instance trade and financial measures). In this situation, you may need to apply to the relevant bodies for more than one licence.

More information

For further information on financial sanctions, contact the Office of Financial Sanctions Implementation at OFSI@hmtreasury.gov.uk or subscribe to OFSI’s e-alerts.

For further information on trade sanctions, contact the Export Control Joint Unit Helpline on +44 (0) 20 7215 4594 or email exportcontrol.help@trade.gov.uk, importcontrols@trade.gov.uk, or subscribe to the Export Control Joint Unit’s Notices to Exporters.

For further information on transport sanctions, contact the Department for Transport on transportsanctions@dft.gov.uk

For further information on immigration sanctions, contact the Home Office on public.enquiries@homeoffice.gov.uk.

For general information on sanctions, contact the Foreign, Commonwealth & Development Office’s Sanctions Unit on sanctions@fcdo.gov.uk.

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