Myanmar sanctions: statutory guidance
Updated 25 March 2026
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Introduction
This guidance is about the financial, director disqualification, trade and immigration sanctions imposed by The Myanmar (Sanctions) Regulations 2021 (‘the Regulations’).
About the Regulations
The Regulations impose sanctions for the purposes of promoting peace, stability and security in Myanmar; promoting respect for democracy, the rule of law and good governance in Myanmar, including in particular promoting the successful completion of Myanmar’s transition to a democratic country; discouraging actions, policies or activities which repress the civilian population in Myanmar; and promoting compliance with international human rights law and respect for human rights in Myanmar.
For more details see regulation 4: Purposes.
The legislation.gov.uk webpage tells you if the Regulations are up to date or if there are outstanding amendments. You can also view previous versions using the timeline and a list of the legislation that has affected the regulations.
About this guidance
As required by section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign, Commonwealth and Development Affairs has provided this guidance to support compliance with the Regulations.
This guidance is designed to give an overview of the prohibitions and requirements, the enforcement of these, and the circumstances in which exceptions and licences may be used. Where appropriate, it directs you to further detailed guidance to read alongside. See all updates to check this guidance is current.
1. Prohibitions and requirements
Sanctions regulations apply to:
- any individual, business or organisation undertaking activities anywhere in the UK (including the territorial sea)
- any business or organisation incorporated or constituted under the law of any part of the UK undertaking activities anywhere in the world
- any UK national, wherever they are in the world
For full details see section 21 of the Sanctions Act.
The maritime enforcement powers contained in Part 9 of the Regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.
It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent the prohibitions imposed by the Regulations or to enable or facilitate a breach of those prohibitions.
If you are unclear about any aspects of the Regulations, in particular about whether action you are considering taking could breach the Regulations, you are advised to seek independent legal advice.
1.1 Designation of persons
Designation of persons provisions are contained in Part 2 of the Regulations.
The Regulations provide that the Secretary of State may designate persons for the purposes of financial, and/or director disqualification and/or immigration sanctions if they are an ‘involved person’ (as defined in regulation 6), for example if they are, or have been, involved in a specified activity such as undermining democracy, the rule of law or good governance in Myanmar.
The UK Sanctions List contains the names of all designated persons (DPs) and the sanctions that have been imposed on them. Checking the UK Sanctions List is an essential part of due diligence for many firms and other organisations.
1.2 Financial sanctions
Financial sanctions provisions are contained in Part 3 of the Regulations.
Asset freeze and making available provisions
The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly.
These prohibitions also apply in relation to entities owned or controlled by a designated person.
If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the Regulations, you must immediately:
- stop dealing with them
- freeze any assets you are holding for them
- inform OFSI as soon as possible
The Office of Financial Sanctions Implementation (OFSI) is the authority responsible for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. See more about how OFSI implements financial sanctions.
1.3 Director disqualification sanctions
Director disqualification provisions are contained in Part 3A of the Regulations.
Persons designated under regulation 5 for the purpose of director disqualification sanctions under regulation 16A are disqualified from:
- being a director of a UK company
- directly or indirectly taking part in or being concerned in the promotion, formation or management of a UK company
- being a director of a foreign company that has sufficient connection to the UK, even if it is not registered, for example, if it carries out business or has assets in the UK
under the provisions of:
- section 11A of the Company Directors Disqualification Act 1986 (CDDA)
- Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O)
Companies House and the Department for the Economy (Northern Ireland) are responsible for recording information about director disqualification sanctions in their respective Disqualified Director Registers. Companies House is responsible for annotating the Companies Register and preventing registration of a disqualified director’s appointments.
See more information about director disqualification sanctions.
1.4 Trade sanctions
Trade sanctions provisions are contained in Part 5 of the Regulations.
The Regulations impose trade prohibitions relating to:
- military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
- dual-use goods and technology (as specified in Annex 1 to Council Regulation 428/2009 as retained by the European Union (Withdrawal) Act 2018 (the ‘Dual-Use Regulation’)
- goods and technology which might be used for internal repression in Myanmar (as specified in Schedule 2 to the Regulations)
- goods and technology which might be used for the monitoring and interception of telecommunications (as specified in Schedule 3 to the Regulations)
- provision of interception and monitoring services to or for the benefit of the Government of Myanmar
- provision of technical assistance, armed personnel, financial services or funds or associated brokering services to or for the benefit of the Tatmadaw (or persons acting on its behalf or under its direction) where such provision relates to the military activities of the recipient, or otherwise enables or facilitates the conduct of armed hostilities, in Myanmar
Technical guidance on interception and monitoring is available.
There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.
Further detail on these trade prohibitions, including key terminology used, is explained below. The Regulations contain full definitions of all terms.
Export of goods
The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act, which clarifies that ‘export’ means export from the UK, but does not capture where goods are removed to the Isle of Man from the UK.
The export prohibition in the Regulations covers export to Myanmar as well as exports that are for use in Myanmar. This means that, even if the immediate destination is not Myanmar, the prohibition may still apply. Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they know or think the items may be used in Myanmar.
The export prohibition in regulation 30 prohibits the export to Myanmar of dual-use goods for military use, the export of dual-use goods for military use in Myanmar and the export of dual-use goods to, or for use by, the Myanmar security forces. ‘For military use’ is defined at regulation 29.
A sanctions licence is not required for exports of non-military goods covered by the Regulations from Northern Ireland to an EU Member State where the final destination is Myanmar. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Myanmar. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.
Supply and delivery of goods
Supply and delivery prohibitions in the Regulations prohibit a person from directly or indirectly supplying or delivering goods from a third country to a place in Myanmar. Regulation 23(4) specifies that for the purposes of this regulation a third country is a country that is not the UK, Isle of Man or Myanmar.
Regulation 31 prohibits a person from directly or indirectly supplying or delivering dual-use goods for military use from a third country to a place in Myanmar and supplying or delivering dual-use goods from a third country to, or for use by, the Myanmar security forces.
Making goods and technology available
Prohibitions in the Regulations on making restricted goods or technology available (e.g. through a sale) include directly or indirectly making them available for use in Myanmar or to a ‘person connected with Myanmar’. Regulation 21(4) sets out when a person is to be regarded as ‘connected with’ Myanmar (and this applies where the term is used in other trade prohibitions in this Part of the Regulations).
Regulation 32 prohibits a person from directly or indirectly making available dual-use goods for military use or dual-use technology for military use to a person connected with Myanmar or for military use in Myanmar, and also prohibits the direct or indirect making available of dual-use goods to or for use by the Myanmar security forces.
Transfer of technology
Prohibitions in the Regulations on the transfer of restricted technology include transfer to a place in Myanmar or a person ‘connected with’ Myanmar.
The transfer of dual-use technology for military use to a place in Myanmar, to a person connected with Myanmar and the transfer of dual-use technology to the Myanmar security forces is also prohibited.
The term ‘transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act, which states that it ‘means a transfer by any means (or combination of means), including oral communication and the transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.’
Where restricted or dual-use technology is contained within a good, it would be classified as a restricted or dual-use good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like.
Technical assistance
The term ‘technical assistance’ in relation to goods or technology is defined in regulation 21, which states that it means:
- technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
- any other technical service relating to the goods or technology
Prohibitions apply where the technical assistance relates to restricted goods or technology.
The prohibitions apply to the direct or indirect provision of such technical assistance (1) to persons ‘connected with’ Myanmar or (2) for use in Myanmar.
This means that, even if the person to whom you are providing the relevant technical assistance is not in or ‘connected with Myanmar’, the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Myanmar. Therefore, if you are providing technical assistance you should check whether the goods or technology may be used in Myanmar and apply for a licence or contact ECJU if so.
Regulation 34(1) also prohibits the direct or indirect provision of technical assistance relating to dual-use goods for military use or dual-use technology for military use to a person connected with Myanmar, for military use in Myanmar and provision of technical assistance relating to dual-use goods or dual-use technology to or for use by the Myanmar security forces.
Financial services and funds related to goods and technology
‘Financial services’ refers to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.
‘Funds’ means financial assets and benefits of every kind, including cash, securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.
Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.
The prohibitions in the Regulations apply to the direct or indirect provision of financial services, and the direct or indirect making available of funds, to persons connected with Myanmar in pursuance of or in connection with an arrangement set out in regulation 27(1). This captures arrangements where the object or effect falls into one of the prohibitions, for example the export of goods or direct or indirect supply or delivery of goods.
Regulation 35 prohibits the direct or indirect provision of financial services, and the direct or indirect making available of funds, to persons connected with Myanmar in pursuance of or in connection with an arrangement set out in regulation 35(1). This captures arrangements where the object or effect falls into one of the prohibitions concerning dual-use goods or technology for military use. Regulation 35 also prohibits the direct or indirect provision of financial services or funds to the Myanmar security forces in pursuance of or in connection with an arrangement set out at regulation 35(3).
The Regulations also prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with specific arrangements as set out in regulation 27(3) or regulation 35(4).
Brokering services
The definition of ‘brokering services’ is set out in regulation 21, which states that it means any service to secure, or otherwise in relation to, an arrangement, including (but not limited to):
- the selection or introduction of persons as parties or potential parties to the arrangement
- the negotiation of the arrangement
- the facilitation of anything that enables the arrangement to be entered into, and
- the provision of any assistance that in any way promotes or facilitates the arrangement
The Regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are set out in regulation 28 and 36.
Other service provisions
Certain other services are prohibited in the Regulations.
Provisions on interception and monitoring services are set out in Regulation 37 and relate to the provision of such services to or for the benefit of the Government of Myanmar. The Government of Myanmar is defined as including its public bodies, corporations or agencies or any person acting on its behalf or at its direction. The definition of ‘interception and monitoring services’ is set out in Regulation 20.
The Regulations also prohibit the direct or indirect provision of the following, to or for the benefit of the Tatmadaw (or to any person acting on its behalf or under its direction) where such provision relates to the military activities of the recipient in Myanmar or otherwise enables or facilitates the conduct of armed hostilities in Myanmar:
a) technical assistance
b) armed personnel
c) financial services or funds, or
d) brokering services in relation to an arrangement whose object or effect is to provide, in a non-UK country anything mentioned in paragraphs (a) - (c)
Trade sanctions enquiries
The Department for Business and Trade (DBT) leads on trade sanctions. For help with export controls or trade sanctions, contact the Export Control Joint Unit, part of DBT, on: exportcontrol.help@businessandtrade.gov.uk or tradesanctions@businessandtrade.gov.uk
Helpline: +44 (0)20 7215 4594
For queries about interception and monitoring services sanctions, contact the Office of Trade Sanctions Implementation (OTSI).
1.5 Immigration sanctions
Immigration sanctions provisions are contained in Part 4 of the Regulations.
The effect of the Regulations is to impose a travel ban on persons who are designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of section 8B of the Immigration Act 1971.
Designated individuals 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 under the Regulations, 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.
If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.
See more information on how the Home Office deals with those who are subject to a travel ban.
1.6 Information and record-keeping
Information and record-keeping provisions, including financial sanctions reporting obligations, are contained in Part 7 of the Regulations.
Financial sanctions reporting obligations and information requests
For the purpose of the financial sanctions, the Regulations place obligations on relevant firms to report information to HM Treasury (in practice to the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury) about known or suspected designated persons or about persons who may have breached a prohibition or failed to comply with an obligation under specified provisions of the Regulations.
OFSI has powers to request information from, among others, a designated person, including powers to request the production of documents. It is an offence to fail to comply with these requests or provide false information.
If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
See more guidance about OFSI’s reporting obligations.
Trade sanctions reporting obligations and information requests
The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) (TASSCER) Regulations (2024) place obligations on relevant persons (providers of financial or legal services, or money service businesses, for example) in relation to suspected breaches of certain trade sanctions.
For details see Trade sanctions: reporting obligations.
The Regulations establish powers to request information in relation to the trade sanctions and record-keeping responsibilities for licences. It is an offence to fail to comply with any of these requirements or intentionally obstruct an official in the exercise of these powers.
See more details about information you must provide in response to a trade sanctions information request.
If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
2. Enforcement
Enforcement provisions are contained in Part 8 of the Regulations.
It is a criminal offence to breach sanctions, or to enable or facilitate a breach of, or to circumvent sanctions. The Regulations set out the mode of trial and penalties that apply to such offences.
In some cases, offences are contained in other legislation, such as the Customs and Excise Management Act 1979 (CEMA), or in the regulations made under the Sanctions Act that apply across regimes, such as the TASSCER regulations.
2.1 Financial sanctions enforcement
A breach of the main financial prohibitions or licensing provisions in the Regulations is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 7 years’ imprisonment or a fine, or both.
Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.
The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose civil monetary penalties and refer cases to law enforcement agencies for criminal investigation and potential prosecution.
OFSI’s approach to compliance and enforcement is outlined in section 7 of OFSI’s general guidance.
For more information about how OFSI assesses suspected breaches and the possible enforcement outcomes, see OFSI’s enforcement guidance.
2.2 Director disqualification sanctions enforcement
A breach of the main prohibitions or licensing provisions is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.
It is also an offence to provide misleading information to obtain a licence, act outside of permissions given or ignore conditions contained within a licence. A licensing offence carries a maximum sentence on conviction on indictment of 2 years’ imprisonment, or a fine, or both.
The Insolvency Service is responsible for investigating suspected breaches and licensing offences. It has the power to bring prosecutions for breaches and refer cases to other law enforcement agencies for criminal investigation and potential prosecution.
2.3 Trade sanctions enforcement
A breach of the trade sanctions prohibitions is triable either way and carries a maximum sentence on conviction on indictment of 10 years’ imprisonment or a fine, or both.
A breach of the trade sanctions licensing provisions is also triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.
Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.
HM Revenue and Customs (HMRC) is responsible for the enforcement of trade sanctions that fall within its remit as the UK’s customs authority and for the enforcement of trade sanctions measures that relate to strategic goods and technology.
If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible. If the irregularity was found on an Export Control Joint Unit compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.
The Office of Trade Sanctions Implementation (OTSI), part of DBT, is responsible for the civil enforcement of certain trade sanctions including for standalone services and the movement of goods involving UK companies or persons that do not cross the UK border. For information about how OTSI assesses breaches and the possible enforcement outcomes, see OTSI’s enforcement guidance.
3. Exceptions and licences
Exceptions and licensing provisions are contained in Part 6 of the Regulations.
3.1 Exceptions
An exception gives an automatic exemption to an activity that would otherwise be prohibited under sanctions. It means you can carry out that activity as long as certain defined circumstances, set out in the Regulations, apply to your activity.
An exception applies automatically so you do not require a licence to carry out the proposed activity, but some exceptions have notification obligations.
To check the full legal wording of an exception, go to the regulations listed in Part 6. If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.
General exceptions
Exception for authorised conduct in a relevant country (regulation 42)
This exception relates to prohibitions in regulations 11 to 15 and Chapters 2 to 5 of Part 5 (Trade).
The exception applies if:
- conduct is authorised by a licence or other authorisation that is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition
Exception for acts done for purposes of national security or prevention of serious crime (regulation 43)
This exception can be used in relation to any prohibition or requirement imposed by the Regulations.
The exception applies if:
- a responsible officer has determined the relevant actions to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere
Financial sanctions exceptions
Exceptions for crediting a frozen account (regulation 41)
These exceptions relate to the prohibitions in regulations 11 to 13 about dealing with the funds or economic resources of designated persons and making funds available to them. The exceptions permit, in certain circumstances, frozen accounts to be credited by and transfers made to ’relevant institutions’ – those with permission to carry out regulated activities under the Financial Services and Markets Act 2000 part 4A.
See section 6 of OFSI’s general guidance for details about how to use these exceptions and the related reporting obligations for relevant institutions.
Exception for required payments (regulation 41A)
This exception relates to the prohibitions in regulations 11 and 13 about dealing with the funds or economic resources of designated persons and making funds available for their benefit.
The exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.
See OFSI’s FAQs on required payments for details about how to use these exceptions and the related notification obligations.
3.2 Licensing for financial sanctions
A licence is a written permission from OFSI that allows an act that would otherwise be in breach of the financial sanctions prohibitions set out in the Regulations.
OFSI has issued general licences that may be used under this regime. For details see OFSI’s general licence page.
In circumstances where there are no applicable exceptions from the prohibitions or general licences, any person (including a designated person) may apply for a licence from OFSI enabling them to deal with the frozen funds or economic resources of the designated person, or to allow these to be made available to or for the benefit of a designated person.
You should not assume that a licence will be granted or engage in any activities prohibited by financial sanctions until your licence has been granted.
Licensing grounds for financial sanctions
OFSI can only issue individual licences where:
- there is a relevant licensing ground
- the conditions set out in that licensing ground have been met, and
- OFSI considers it appropriate to issue a licence for that purpose
The purposes and activities for which OFSI may grant an individual licence are set out in Schedule 4 to the Regulations. In summary these are:
- basic needs
- reasonable professional fees for or reasonable expenses associated with the provision of legal services
- reasonable fees or service charges arising from the routine holding or maintenance of frozen funds or economic resources
- extraordinary expenses
- judicial decisions etc
- diplomatic missions etc
- extraordinary situation
- prior obligations
- humanitarian assistance activities etc
- insolvency
See section 6.6 of OFSI’s general guidance for the approach OFSI takes when deciding whether to grant a licence for each of these licensing grounds.
See OFSI’s licensing page for licence application forms and guidance.
3.3 Licensing for director disqualification sanctions
The designated person, or their authorised representative, can make an application for a licence to the Insolvency Service. See more details about how to apply.
The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. Companies House is responsible for updating the Companies Register when a licence is granted.
You should not assume that a licence will be granted or act as the director of a company – or directly or indirectly take part in or be concerned in the promotion, formation or management of a company – until your licence has been granted.
3.4 Licensing for trade sanctions
Licences may also be issued for certain trade activities that would otherwise be prohibited by the Regulations. The Department for Business and Trade (DBT) has overall responsibility for trade sanctions licensing. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.
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.
The Export Control Joint Unit (ECJU), part of DBT, is responsible for licensing the export of (otherwise sanctioned) goods, software and technology. See guidance on how to apply for an export licence. Information on the activities you wish to carry out and any other relevant documentation can be provided in a cover letter and attached to the application. If you have questions on trade sanctions licensing, contact tradesanctions@businessandtrade.gov.uk
DBT’s Import Controls team is responsible for licensing the import of (otherwise sanctioned) goods, software and technology. See guidance on how to apply for an import licence. The Import Controls team will, to the extent possible, aim to inform the trader of the application outcome within 30 days. However, in some circumstances, for operational or legal reasons, DBT may need to take longer than the 30 day period. They will inform the applicant if this is the case.
The Office of Trade Sanctions Implementation (OTSI) can issue licences for (otherwise sanctioned) interception and monitoring services.
DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.
In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 5 of the Regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.
For some prohibitions there are some specific activities that DBT considers are likely to be consistent with the aims of the sanctions. These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions you should make this clear and explain why you believe this to be the case in your application for a licence.
You should not assume that a licence will be granted or engage in any activities prohibited by the trade sanctions until your licence has been granted.
Considerations for trade sanctions licences
| Prohibitions | Type of consideration |
|---|---|
| Regulations 22 to 25 | Considerations for the export, making available, transfer, supply or delivery of military goods or technology |
A licence may be granted for the export, making available, transfer, supply or delivery of non-lethal military goods or technology if the goods or technology are intended solely for humanitarian or protective use.
A licence may be granted for the export, making available, transfer, supply or delivery of non-lethal military goods or technology if the goods or technology are intended solely for UK Government or UN institution-building programmes or crisis management operations.
A licence may be granted for the export, making available, transfer, supply or delivery of de-mining goods or technology if the goods or technology are for use in de-mining operations.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 26 and 27 | Considerations for the provision of technical assistance, financial services or funds relating to military goods or technology |
A licence may be granted for the provision of technical assistance, financial services or funds related to non-lethal military goods or technology if the technical assistance, financial services or funds relate to goods or technology which are intended solely for humanitarian or protective use.
A licence may be granted for the provision of technical assistance, financial services or funds related to military goods or technology if the technical assistance, financial services or funds relate to goods or technology which are intended solely for UK Government or UN institution-building programmes or crisis management operations.
A licence may be granted for the provision of technical assistance, financial services or funds related to de-mining goods or technology if the technical assistance, financial services or funds relate to goods or technology which are for use in de-mining operations.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 30 to 33 | Considerations for the export, making available, transfer, supply or delivery of dual-use goods or technology |
A licence may be granted for the export, making available, transfer, supply or delivery of dual-use goods or technology if the goods or technology are intended solely for humanitarian or protective use.
A licence may be granted for the export, making available, transfer, supply or delivery of dual-use goods or technology if the goods or technology are intended solely for UK Government or UN institution-building programmes or crisis management operations.
A licence may be granted for the export, making available, transfer, supply or delivery of dual-use goods or technology if it relates to the execution of contracts concluded before 27 April 2018 or ancillary contracts necessary for the execution of such contracts.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 34 to 35 | Considerations for the provision of technical assistance, financial services or funds relating to dual-use goods or technology |
A licence may be granted for the provision of technical assistance, financial services or funds related to dual-use goods or technology if the technical assistance, financial services or funds relate to goods and technology which are intended solely for humanitarian or protective use.
A licence may be granted for the provision of technical assistance, financial services or funds related to dual-use goods or technology if the technical assistance, financial services or funds relate to goods or technology which are intended solely for UK Government or UN institution-building programmes or crisis management operations.
A licence may be granted for the provision of technical assistance, financial services or funds related to de-mining goods or technology if the technical assistance, financial services or funds relate to goods or technology for use in de-mining operations.
A licence may be granted for the provision of technical assistance, financial services or funds related to dual-use goods or technology if the technical assistance, financial services or funds relate to the execution of contracts concluded before 27 April 2018 or ancillary contracts necessary for the execution of such contracts.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 22 to 25 | Considerations for the export, making available, transfer, supply or delivery of goods or technology which might be used for internal repression |
A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology that might be used for internal repression if the goods or technology are intended solely for humanitarian or protective use.
A licence may be granted for the export, making available, transfer, supply or delivery of goods or technology that might be used for internal repression if the goods or technology are intended solely for UK Government or UN institution-building programmes or crisis management operations.
A licence may be granted for the export, making available, transfer, supply or delivery of de-mining goods or technology if the goods or technology are for use in de-mining operations.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 26 and 27 | Considerations for the provision of technical assistance, financial services or funds relating to goods or technology which might be used for internal repression |
A licence may be granted for the provision of technical assistance, financial services or funds related to goods or technology that might be used for internal repression if the technical assistance, financial services or funds relate to goods or technology which are intended solely for UK Government or UN institution-building programmes or crisis management operations.
A licence may be granted for the provision of technical assistance, financial services or funds related to de-mining goods or technology if the technical assistance, financial services or funds relate to goods or technology for use in de-mining operations.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 22 to 25 | Export, making available, transfer, supply or delivery of goods or technology which might be used for the monitoring and interception of telecommunications |
A licence will not be granted for the export, making available, transfer, supply or delivery of interception and monitoring goods or technology if the Secretary of State has reasonable grounds to determine that the goods or technology would be used for internal repression by the Government of Myanmar.[footnote 1]
| Prohibitions | Type of consideration |
|---|---|
| Regulations 26 and 27 | Provision of brokering services, technical assistance, financial services or funds relating to goods or technology which might be used for the monitoring and interception of telecommunications |
A licence will not be granted for the provision of brokering services, technical assistance, financial services or funds related to interception and monitoring goods or technology if the technical assistance, financial services or funds relate to goods or technology that the Secretary of State has reasonable grounds to determine would be used for internal repression by the Government of Myanmar [footnote 1].
| Prohibitions | Type of consideration |
|---|---|
| Regulation 37 | Provision of interception and monitoring services |
A licence will not be granted for the provision of interception and monitoring services if the Secretary of State has reasonable grounds to determine that the services would be used for internal repression by the Government of Myanmar [footnote 1].
| Prohibitions | Type of consideration |
|---|---|
| Regulation 38 | Provision of technical assistance, armed personnel, financial services or funds or brokering services relating to military activities or otherwise enabling or facilitating the conduct of armed hostilities |
A licence may be granted for the provision of technical assistance, armed personnel, financial services or funds or brokering services relating to military activities of the Tatmadaw or any person acting on its behalf or under its direction or otherwise enabling and facilitating the conduct of armed hostilities if it amounts to training or cooperation aimed at strengthening democratic principles, the rule of law or respect for international law including international human rights law in Myanmar.
When you export goods, you may need to submit an electronic export declaration: guidance is available on how to make an export declaration.
Overlap with strategic export licensing
Military goods and military technology
Please note that the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.
The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the Regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.
The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the Regulations.
Dual-use goods and technology
Please note that the export of and trade in dual-use goods and technology are also controlled under the Dual-Use Regulation. Authorisations under that Regulation are granted by the Secretary of State for Business and Trade under licensing powers in the Export Control Order 2008.
This means that all licence applications relating to items which are controlled dual-use goods and technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if an authorisation is refused for the same activity under the Dual-Use Regulation.
As explained above in relation to military goods and technology, only a single licence application will be required in relation to dual-use goods and technology which falls within the scope of both the Regulations and the Dual-Use Regulation. If the application is compatible with both criteria, a licence will be granted which will be valid under the Dual-Use Regulation and the Export Control Order 2008 as well as the Regulations.
Overlap between trade sanctions and financial sanctions
If you import or export goods or services, you need to consider if financial sanctions apply to you. You may need a licence from OFSI as well as from ECJU, OTSI or the Import Controls Team. See the guidance on licensing for more details.
Transit control
Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for Myanmar, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Myanmar.
3.5 Directions in respect of immigration sanctions
If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.
4. Further information
The UK sanctions hub page is a central point for all sanctions content, including links to introductory guidance, sector-specific guidance, reporting obligations, blogs, and email alert services.
You can report a suspected breach of sanctions if you think you, or someone else, may have breached sanctions, or be attempting to circumvent sanctions.
For specific queries about this sanctions regime, email: fcdo.correspondence@fcdo.gov.uk
For other contact details, see Government departments and agencies responsible for sanctions.