Overview of UK sanctions

Sanctions are restrictive measures that can be put in place to fulfil a range of purposes. In the UK, 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.

As required under section 30 of the Sanctions Act, the Foreign, Commonwealth & Development Office published the Sanctions Regulations Report on Annual Reviews for 2021.

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

Find out:

• more information on UK sanctions policy from 11pm on 31 December 2020
• where UK sanctions regimes apply
• how to request a review of a sanctions decision
• how to request the review of the specification or designation of a ship
• who is subject to UK sanctions under the Sanctions Act

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 Consolidated List of Asset Freeze Targets, which contains details of designations specifically for financial sanctions, where asset freeze measures apply.

Trade sanctions

The Department for Business and Trade (DBT) 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

DBT’s Export Control Joint Unit (ECJU) administers the UK’s system of export controls and is responsible for licensing the export of goods, software and technology from the UK, including issuing licences for the export of goods and the provision of ancillary services to sanctioned destinations.

DBT’s Import Licensing Branch implements trade sanctions relating to imports.

The Office of Trade Sanctions Implementation (OTSI) is responsible for supporting businesses with trade sanctions compliance; issuing licences for the provision of sanctioned standalone services, including professional and business services; and detecting and responding to suspected breaches, including taking appropriate and proportionate enforcement action where necessary.

HMRC is responsible for the criminal enforcement of all trade sanctions measures, and enforces trade sanctions on goods crossing the border in line with its role as the UK’s customs body.

OTSI is responsible for civil enforcement of certain trade sanctions and the movement of goods involving UK companies and persons which do not cross the UK border. 

This includes:

• the movement of goods and technology outside the UK 

• the provision or procurement of services insofar as they relate to the movement of goods outside of the UK (“ancillary services”) 

• the making available, or acquisition of goods and technology outside the UK 

• the making available or acquisition of land 

• the conduct of activities relating to military activities 

• the provision or procurement of services

Find out:

• where arms embargoes and other trade restrictions apply
• export controls: military goods, software and technology
• export controls: dual-use items, software and technology
• how to apply for a licence in respect of trade sanctions
• how to report a trade sanctions breach

Financial sanctions

HM Treasury implements and enforces financial sanctions, through its Office of Financial Sanctions Implementation (OFSI). OFSI 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 for an activity that would otherwise be prohibited by financial sanctions regulations, under certain circumstances.

Find out:

• who is subject to UK financial sanctions under the Sanctions Act, EU legislation and other financial sanctions legislation
• how to apply for a financial sanctions licence
• how to report a potential breach of financial sanctions
• more information about financial sanctions

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.

Find out:

• how to apply for an aircraft or shipping licence
• how to report an aircraft or shipping sanctions breach

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.

Find out:

• more about entering and staying in the UK

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 would otherwise prohibit.

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out. 

If you are carrying out activity that falls under the remit of more than one licensing body, you will need to submit separate licence applications for each one. 

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

Licensing for financial sanctions

Licences may be issued to allow for certain activities that financial sanctions restrictions 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 (OFSI) 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 furthertimely updatesnotifications about all new and detailsupdated designations, sanctions announcements, and updates on designations,sanctions subscribeguidance, sign up to FCDO’sget e-alertsUK sanctions email alerts.

For further information on financial sanctions, contact the Office of Financial Sanctions Implementation (OFSI) helpline on +44 (0) 207270 5454 or at OFSI@hmtreasury.gov.ukofsi@hmtreasury.gov.uk or subscribe to OFSI’s e-alerts.

For further information on export controls and trade sanctions relating to exporting goods and providing ancillary services, contact ECJU.

For further information on trade sanctions relating to the provision of standalone services, including professional and business services, contact OTSI. 

For further information on import controls, contact DBT’s Import Licensing Branch on importcontrols@businessandtrade.gov.uk

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 Directorate on fcdo.correspondence@fcdo.gov.uk