Petroleum products humanitarian assistance exception: notification form

This form is for certain ‘relevant persons’ relying on the humanitarian assistance exception from the prohibitions in regulations 12 to 15 under the Syria (Sanctions) (EU Exit) Regulations 2019.  

This exception applies when a ‘relevant person’ makes available funds or economic resources either to acquire, supply or deliver petroleum products or to provide funds, economic resources or financial services in relation to that, if:   

• the petroleum products are exclusively for the purposes of providing a humanitarian assistance activity, and   
• the relevant person is  one of those listed in regulation 57 (7) 

For full details about the exception, see regulation 57 of the Syria (Sanctions) (EU Exit) Regulations 2019. 

Notification requirement 

If you are within the scope of the UK sanctions regime and make funds or economic resources available in reliance on this exception, the Regulations require you to notify the Treasury (via the Office of Financial Sanctions (OFSI)) that you are involved in the provision of humanitarian assistance activities in Syria by the end of the calendar year in which those activities take place.   

The notification requirement does not apply to ‘relevant persons’ falling under limbs (b) or (f) of the definition set out in regulation 57(7), to humanitarian organisations having observer status with the United Nations General Assembly, or to the British Red Cross. 

Annual notification 

It is suggested that relevant persons conducting humanitarian assistance activities in Syria who may need to rely on the exception but are not certain whether they need to do so, notify OFSI on an annual basis. This will make compliance easier for those that do need to rely on the exception. Notification to OFSI that a relevant person is involved in the provision of humanitarian assistance activities in Syria can be done without prejudice: it does not amount to confirmation that the exception has in fact been relied on and that notification is therefore required, nor an admission that those activities would otherwise breach sanctions.

Changes in April 2025 

Note that from 25 April 2025 both the exception and the notification requirement only apply in relation to the prohibitions in regulations 12 to 15 – making funds or economic resources available to, or for the benefit of, designated persons. 

This is because the prohibitions on the purchase, acquisition and transport of petroleum products, and related services, were lifted in April 2025, so the exception is no longer needed in relation to those prohibitions. 

Changes in 2024 

The 2024 amendments to the humanitarian assistance exception to the petroleum provisions were aimed at improving the overall efficiency and usability of the exception, and included: 

• expanding the list of persons eligible to rely upon it 
• introducing a different notification requirement, and  
• clarifying record-keeping obligations  

For more information, see the explanatory memorandum to the Syria (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024.