Statutory guidance

Republic of Belarus sanctions: statutory guidance

Updated 12 March 2026

Introduction

This guidance is about the financial, director disqualification, trade, transport and immigration sanctions imposed by The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (‘the Regulations’).

About the Regulations

The Regulations impose sanctions for the purposes of encouraging the Government of Belarus to:

• respect democratic principles and institutions and the separation of powers and the rule of law in Belarus
• refrain from actions, policies or activities which repress civil society in Belarus
• investigate properly and institute criminal proceedings against persons responsible for the disappearances of Yury Zakharanka, Viktar Hanchar, Anatol Krasouski and Dzmitry Zavadski
• comply with international human rights law and respect human rights
• cease actions destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, including by supporting or facilitating Russia’s actions in respect of Ukraine
• refrain from any other action that undermines or threatens peace, security or stability in Europe

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, and has a timeline that shows previous versions. You can also view a list of the legislation that has affected the regulations, which includes:

• the Republic of Belarus (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2021
• the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022
• the Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023

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

The Regulations provide that the Secretary of State may designate persons by name for the purposes of immigration sanctions, director disqualification and/or certain financial, aircraft, shipping or trade sanctions, if they are an involved person (as defined in regulation 6).

The Regulations also make provision for the Secretary of State to provide that persons of a specified description are designated persons for the above purposes.

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.

Other financial and investment restrictions

It is prohibited to deal with transferable security or money-market instruments issued by a broad range of entities and individuals connected with Belarus and the government of Belarus including those issued by:

• a relevant person (as defined in regulation 15D(1)) (a narrower range of restrictions applies to instruments issued in the period before the 2022 regulations came into force, for transferable security or money-market instruments with a maturity exceeding 90 days)
• a person connected with Belarus (this is defined in regulation 2(2) and is subject to the exclusions in regulation 15B(2C)(a))
• an entity majority owned by a person connected with Belarus

Loan and credit arrangements

The Regulations prohibit a person from directly or indirectly granting, or entering into an arrangement to grant:

• a loan or credit with a maturity exceeding 90 days, granted after noon on 9 August 2021 and before 5 July 2022 to a ‘relevant person’ (as set out above), which is classed as a category A loan
• a loan or credit on or after 5 July 2022 to a ‘relevant person’ (as set out above), which is classed as a category B loan
• a loan or credit on or after 5 July 2022 with a maturity exceeding 30 days granted to a person connected with Belarus (this is defined in regulation 2(2), and is subject the exclusions in regulation 15B(5)), which is classed as a category C loan

Insurance and reinsurance services

A person must not provide insurance or reinsurance services to:

• Belarus
• a Belarusian authority (as defined in regulation 15D(1))
• an entity wholly owned by Belarus or a Belarusian authority
• anyone acting on their behalf or at their direction

This prohibition does not apply to persons who are in charge of a ship or aircraft and who are temporarily acting at the direction of the Belarusian authorities etc, for certain specified purposes.

Provision of financial services for the purpose of foreign exchange reserve and asset management

The Regulations prohibit a UK individual or entity from providing financial services for the purpose of foreign exchange reserve and asset management to:

• the National Bank of Belarus
• the Ministry of Finance of Belarus
• a person owned or controlled directly or indirectly by any of the persons above; or
• a person acting on behalf of or at the direction of any of the persons above

‘Foreign exchange reserve and asset management’ means activities relating to the reserves or assets of the persons listed above. Such reserves or assets include money market instruments (including cheques, bills and certificates of deposit); foreign exchange; derivative products (including futures and options); exchange rate and interest rate instruments (including products such as swaps and forward rate agreements); transferable securities; other negotiable instruments and financial assets (including bullion); and special drawing rights.

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 19B 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

The Regulations impose trade prohibitions relating to:

• military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
• any thing which falls within Chapter 93 of the Goods Classification Table^{[footnote 1]}, other than military goods
• provision of technical assistance, armed personnel, financial services or funds, or associated brokering services where such provision enables or facilitates the conduct of certain military activities
• dual-use goods and technology (as specified in Annex I to Council Regulation 428/2009 as retained by the European Union (Withdrawal) Act 2018 (‘the Dual-Use Regulation’))
• internal repression goods and technology (as specified in Schedule 2 to the Regulations)
• interception and monitoring goods and technology (as specified in Schedule 2A to the Regulations, but excluding goods and technology specified in Schedule 2 to the Export Control Order 2008, or Annex I to the Dual-Use Regulation)
• interception and monitoring services
• technical assistance relating to aircraft and ships
• tobacco industry goods (as specified in Schedule 2B to the Regulations)
• potash (as specified in Schedule 2B to the Regulations)
• mineral products (as specified in Schedule 2B to the Regulations)
• iron and steel products (as specified in Schedule 2B to the Regulations)
• critical industry goods and technology (as specified in Schedule 2C of the Regulations)
• luxury goods (as specified in Schedule 2E or the Regulations)
• oil refining goods and technology (as specified in Schedule 2F of the Regulations)
• quantum computing and advanced materials goods and technology (as specified in Schedule 2G of the Regulations)
• chemical and biological weapons-related goods and technology (as specified in Schedule 2H of the Regulations)
• machinery-related goods and technology (as specified in Schedule 2I of the Regulations)
• banknotes (as specified in Regulation 20(3))
• cement (as specified in Schedule 2J of the Regulations)
• gold and gold jewellery (as specified in Schedule 2J of the Regulations)
• relevant processed gold (as specified in Regulation 20(3))
• rubber (as specified in Schedule 2J of the Regulations)
• wood (as specified in Schedule 2J of the Regulations)
• aluminium (as specified in Schedule 2B of the Regulations)

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.

Aluminium, cement, gold, gold jewellery, iron and steel products, luxury goods, machinery-related goods and technology, mineral products, oil refining goods, tobacco industry goods, potash, and rubber and wood are identified by reference to commodity codes in the Goods Classification Table. The UK Tariff sets out a system for the classification of goods to enable importers to ascertain the applicable rate of import duty for their goods. It is this system of classification that is used in the Regulations in order to determine whether goods are within scope of the prohibitions.

This means that where commodity codes are used in the Regulations, the relevant goods are those which would be classified under the relevant commodity code (applying the rules in the UK Tariff) if the goods were being imported to the UK.

Some of the listings of commodity codes in the Regulations have an ‘ex’ before the code. Where this ‘ex’ appears before a commodity code this means that the prohibitions in the Regulations do not apply to all of the items under that commodity code. The prohibitions will only apply to those items that (1) would be classified under the commodity code and (2) that match the description given next to the relevant ‘ex’ code entry in the Regulations.

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.

Export prohibitions in the Regulations cover export to Belarus as well as exports that are for use in Belarus. This means that, even if the immediate destination is not Belarus, the prohibition may still apply.

The export prohibitions at regulation 21 prohibit the export of banknotes, chemical and biological weapons-related goods, critical-industry goods, dual-use goods, interception and monitoring goods, internal repression goods, luxury goods, machinery-related goods, military goods, oil refining goods, quantum computing and advanced material goods and tobacco industry goods to or for use in Belarus.

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 Belarus.

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 Belarus. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Belarus. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.

Import of goods

The concept of ‘import’ is set out in customs legislation, but is further detailed in Paragraph 33 of Schedule 1 to the Sanctions Act. This clarifies in particular that goods removed to the UK from the Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.

The import prohibition in regulation 27I (aluminium, arms and related materiel, cement, gold and gold jewellery which has been exported from Belarus on or after 9 June 2023, iron and steel products, mineral products, potash, relevant processed gold, rubber and wood) covers goods that are consigned from Belarus and goods that originated in Belarus.

This means that even if the immediate place the goods were shipped from was not Belarus, the prohibition may still apply. Therefore, importers should check the original place goods were consigned from or contact the DBT Import Licensing Branch if they think the items may have originally been consigned from Belarus.

A sanctions licence is not required for imports into Northern Ireland of non-military goods covered by the Regulations from an EU Member State which originate in or are consigned from Belarus. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the original import into the customs territory of the EU. You will also have to comply with any other licensing requirements under UK import 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 Belarus, from a place in Belarus to a third country, or from a place in a non-UK country to another non-UK country. Regulation 22(4) specifies that for the purposes of this regulation a third country is a country that is not the UK, Isle of Man or Belarus.

Regulation 22 prohibits a person from directly or indirectly supplying or delivering banknotes, chemical and biological weapons-related goods, critical-industry goods, dual-use goods, interception and monitoring goods, internal repression goods, luxury goods, machinery-related goods, military goods, oil refining goods, quantum computing and advanced materials goods, and tobacco industry goods from a third country to a place in Belarus.

Regulation 27K prohibits a person from directly or indirectly supplying or delivering aluminium, arms and related materiel, cement, gold and gold jewellery which has been exported from Belarus on or after 9 June 2023, iron and steel products, mineral products, potash, rubber or wood from a place in Belarus to a third country.

The Regulations also prohibit a person from directly or indirectly supplying or delivering cement, gold and gold jewellery which has been exported from Belarus on or after 9 June 2023, mineral products, potash, rubber or wood from a place in a non-UK country to a place in a different non-UK country, where the cement, gold or gold jewellery, potash, mineral products, rubber or wood originate in Belarus.

Making goods and technology available

Prohibitions in the Regulations on making restricted goods and technology available (e.g. through a sale) include directly or indirectly making them available for use in Belarus or to a person ‘connected with’ Belarus. Regulation 2 sets out when a person is to be regarded as ‘connected with’ Belarus (and this applies where the term is used in other trade prohibitions in this Part of the Regulations).

Acquisition of goods and technology

Regulation 27J prohibits a person from directly or indirectly acquiring aluminium, arms and related materiel, cement, gold and gold jewellery which has been exported from Belarus on or after 9 June 2023, iron and steel products, mineral products, potash, rubber, or wood which originate in or are located in Belarus. It also prohibits a person from directly or indirectly acquiring military goods or military technology or potash from a person connected with Belarus.

Regulation 2(2) sets out when a person is to be regarded as ‘connected with’ Belarus.

Transfer of technology

Prohibitions in the Regulations on the transfer of restricted technology include transfer to a place in Belarus or a person ‘connected with’ Belarus.

Regulation 24 prohibits the transfer of chemical and biological weapons-related technology, critical-industry technology, dual-use technology, interception and monitoring technology, internal repression technology, machinery-related technology, military technology, oil refining technology, quantum computing and advanced materials technology to a place in Belarus or to a person ‘connected with’ Belarus.

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 that 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 20, 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 certain specified goods or technology.

The prohibition in regulation 25 applies to the direct or indirect provision of technical assistance relating to relevant goods or technology (1) to persons connected with Belarus or (2) for use in Belarus.

This means that, even if the person to whom you are providing the relevant technical assistance is not in or ‘connected with’ Belarus, the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Belarus. Therefore, if you are providing technical assistance you should check whether the goods or technology may be used in Belarus and apply for a licence or contact ECJU.

Regulation 25 prohibits the direct or indirect provision of technical assistance relating to chemical and biological weapons-related goods and technology, critical industry goods and technology, dual-use goods and dual-use technology, interception and monitoring goods and technology, internal repression goods and technology, machinery-related goods and technology, military goods and technology, oil refining goods and technology, quantum computing and advanced materials goods and technology to a person connected with Belarus or for use in Belarus

Regulation 27L prohibits the direct or indirect provision of technical assistance in relation to prohibited trade in aluminium, cement, gold and gold jewellery which has been exported from Belarus on or after 9 June 2023, iron and steel products, potash, mineral products, relevant processed gold, rubber or wood.

Financial services and funds related to goods and technology

‘Financial services’ refer 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 Belarus in pursuance of or in connection with an arrangement set out in the Regulations. These arrangements are set out in regulations 26 and 27M. This captures arrangements where the object or effect falls into one of the prohibitions, for example the export or import of relevant goods, or the direct or indirect supply or delivery of relevant goods.

These prohibitions also prohibit the direct or indirect provision of financial services or funds in pursuance of or in connection with specific arrangements involving Belarus, as set out in regulations 26(3) and 27M(1).

Brokering services

The definition of ‘brokering services’ is set out in regulation 20, 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

Prohibitions on the provision of brokering services apply where they relate to certain specified goods or technology. The prohibitions apply to the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are set out in regulations 27 and, in relation to aluminium, cement, gold and gold jewellery which has been exported from Belarus on or after 9 June 2023, iron and steel products, potash, mineral products, relevant processed gold, rubber or wood, in regulation 27M.

Other service provisions

Certain other services are prohibited in the Regulations.

These include the provision of certain services which enable or facilitate certain military activities. As set out in regulation 27O, the direct or indirect provision of the following is prohibited where such provision enables or facilitates the conduct of military activities carried on or proposed to be carried on by the Belarusian military or any other military end-user who is a person connected with Belarus:

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 any of the services mentioned in paragraphs (a) to (c)

Prohibitions on interception and monitoring services are set out in regulation 24A and relate to the direct or indirect provision of such services to or for the benefit of the Government of Belarus. The Government of Belarus is defined in regulation 2(1) 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 19A.

Provisions on internet services are set out in regulation 27P and require social media companies, and internet service providers, to take reasonable steps to prevent their users from encountering or accessing services or content online directly generated, shared, uploaded or provided by a designated person. Application store providers must also take reasonable steps to prevent users from using their services to download or access internet services provided by a designated person. Designations for the purposes of these measures will be made by the Secretary of State and published on the UK Sanctions List.

Therefore, if you are an internet service provider, or provide a social media service or application store for internet service applications, then you should check whether an entity has been designated by the UK Government for this purpose and take the necessary action to ensure compliance with the prohibitions.

Technical assistance relating to aircraft and ships

Regulation 27N prohibits the direct or indirect provision of technical assistance to or for the benefit of persons designated for the purpose of this regulation, where that assistance relates to an aircraft or ship.

The persons designated for the purposes of this provision are set out in the UK Sanctions List under ‘sanctions imposed’.

The prohibition applies in relation to any aircraft or ship. You should carry out your own checks to determine to whom, or for whose benefit, you are providing technical assistance relating to aircraft or ships.

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 trade sanctions relating to standalone services, and interception and monitoring services, contact the Office of Trade Sanctions Implementation (OTSI). 

For further information on import controls and sanctions, contact DBT’s Import Controls and Sanctions team on: importsanctions@businessandtrade.gov.uk

1.5 Transport sanctions

Transport sanctions provisions are contained in Parts 5A and 5B of the Regulations and impose transport prohibitions relating to aircraft and shipping.

Aircraft sanctions

The Regulations prohibit a Belarusian aircraft which is owned, chartered or operated by persons connected with Belarus or designated persons from overflying the United Kingdom or landing in the United Kingdom.

In addition, the Regulations provide a power for the Civil Aviation Authority (CAA) to refuse to register an aircraft or for the Secretary of State to direct the CAA to terminate the registration of an aircraft that is owned or operated by a designated person or chartered by a designated person.

The Regulations confer direction making powers for the Secretary of State, air traffic control and airport operators regarding aircraft movements in United Kingdom airspace and at United Kingdom airports. The Regulations also provide a power for the Secretary of State to direct an airport operator to secure the detention of a Belarusian aircraft at an airport or to secure the movement of a Belarusian aircraft to a specified airport.

Belarusian aircraft is defined as an aircraft:

• owned, chartered or operated by a designated person, or a person connected with Belarus, or
• registered in Belarus

Shipping sanctions

The Regulations prohibit Belarusian ships, and other ships specified by the Secretary of State, from entering ports in the United Kingdom. The Regulations also confer powers on the Secretary of State and harbour authorities to issue port barring directions to the master or pilot of a specified ship. The Regulations provide the Secretary of State with a power to control the movement of Belarusian ships or specified ships by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are.

The Regulations prohibit the registration of ships owned, controlled, chartered or operated by designated persons or persons connected with Belarus on the UK Ship Register and confer powers on the Secretary of State to direct the UK Ship Registrar to terminate the registration of such ships.

The Regulations also confer powers on the Secretary of State and harbour authorities to detain Belarusian ships or specified ships at ports or anchorages.

‘Belarusian ship’ is not a term used in the Regulations. However, it is used in this shipping section of the guidance to aid understanding and readability. It means a ship which is:

• owned, controlled, chartered or operated by a designated person
• owned, controlled, chartered or operated by persons connected with Belarus
• registered in Belarus, or
• flying the flag of Belarus

These Regulations do not apply to ships (that are not otherwise included in the Regulations) with Belarusian crews or Masters, unless they are a designated person.

The Department for Transport (DfT) is responsible for implementing the UK’s transport sanctions. See more guidance from DfT. 

For guidance on mandatory reporting to DfT, see Information and record keeping.

1.6 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.

1.7 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.

Part 7 of the Regulations places an obligation on persons designated under the Belarus regime to report the nature, value and location of their assets.

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 and transport 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
• relevant persons (a pilot, airport operator, ship’s master or harbour authority, for example) in relation to suspected breaches of aircraft and shipping sanctions

For details see:

• Trade sanctions: reporting obligations
• Transport 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
• in response to a transport 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.

2.4 Transport sanctions enforcement

In relation to the transport sanctions on movement of aircraft, the following are offences:

• the failure of an operator or pilot of a Belarusian aircraft to comply with the prohibition on overflying the United Kingdom or landing in the United Kingdom
• the failure of an airport operator, without reasonable excuse, to comply with a direction given by the Secretary of State
• the failure of an operator or pilot in command of a Belarusian aircraft to comply with a direction given by air traffic control or an airport operator

All are offences that are triable either way and carry a maximum sentence of 7 years’ imprisonment or a fine (or both).

The Secretary of State may notify a person that the existence or content of a port barring, entry or movement direction and any direction relating to the movement of aircraft, or anything done under such directions, is to be treated as confidential. Disclosure of confidential information is an offence which carries a maximum sentence of 6 months’ imprisonment on summary conviction or a fine (or both).

A breach of the transport sanctions relating to prohibition on port entry, failing to comply with a port barring direction or a port entry or movement direction is an offence that is triable either way and carries a maximum sentence of 7 years’ imprisonment or a fine (or both).

The offence of failing to comply with a detention direction in relation to a ship is triable either way and carries a sentence of a fine.

The Department for Transport (DfT) is ultimately responsible for the implementation of transport sanctions. The enforcement of these sanctions will be supported by the Maritime and Coastguard Agency, harbour authorities, the Civil Aviation Authority (CAA), National Air Traffic Services (NATS) and airport operators.

If you become aware that a breach of the transport prohibitions detailed in the Regulations has taken or will take place, then you must report it as soon as possible by emailing transportsanctions@dft.gov.uk.

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 30A)

This exception relates to prohibitions in regulations 11 to 15, 15B, 15C, 15CA and Chapters 2, 2B and 2C 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 31)

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 30)

These exceptions relate to the prohibitions in regulations 11 to 15 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 30ZA)

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.

Exceptions for the granting of loans and credit (regulation 31A) 

This exception relates to prohibitions in regulation 15B about loans and credit arrangements. 

A loan may be granted where it has a specific and documented objective of making emergency funds available to meet applicable solvency or liquidity criteria for a relevant subsidiary. 

A category A loan (as defined in section 1.2) may be granted where it consists of a drawdown or disbursement made under an arrangement entered into before 9 August 2021, provided that the terms and conditions set out in regulation 31A are met.  

A category B loan (as set out above in section 1.2) or a category C loan (as set out in section 1.2) may also be granted if it consists of a drawdown or disbursement made under an arrangement entered into before 5 July 2022, provided it meets the terms and conditions specified in regulation 31A. 

Exceptions for the provision of insurance and reinsurance services (regulation 31B) 

These exceptions relate to the prohibitions in regulation 15C about the provision of insurance and reinsurance services. 

One exception applies if: 

• the provision of compulsory or third-party insurance is to a Belarusian national or a Belarusian entity located in the UK 

A second exception applies if: 

• the provision of insurance is for a diplomatic mission or consular post of Belarus in the UK 

A third exception applies if: 

• the provision of insurance or reinsurance services to an individual falling within paragraph 2(d) of regulation 15C, is for their personal use

Trade and transport sanctions exceptions

The regulations also set out exceptions relating to some of the trade and transport restrictions.

The exceptions are navigable and scannable in a guide that forms part of this statutory guidance: Look up exceptions to the Belarus trade and transport sanctions.

If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.

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 or to provide financial services for the purposes of foreign exchange reserve and asset management services to the National Bank of Belarus or the Ministry of Finance of the Republic of Belarus.

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 licensing grounds are set out in Schedule 3 to the regulations.

Licensing grounds for financial sanctions

Licensing grounds for asset freeze etc 

The purposes and activities for which OFSI may grant an individual licence to a person, allowing them to deal with their frozen funds or economic resources of a designated person, or to allow for funds or economic resources to be made available to or for the benefit of a designated person are in summary:  

• 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 and consular posts 
• extraordinary situation 
• prior obligations 
• humanitarian assistance activities 
• medical goods and services 
• production or distribution of food 
• insolvency 

Licensing grounds for loans and credit 

The purposes and activities for which OFSI may grant an individual licence in relation to the loans and credit prohibitions in regulation 15B are in summary:  

• humanitarian assistance activity 
• nuclear safety 
• extraordinary situation 
• diplomatic missions or consular posts 
• medical goods or services 
• production or distribution of food 
• insolvency 

Licensing grounds for insurance and re-insurance 

The purposes and activities for which OFSI may grant an individual licence in relation to the insurance and reinsurance prohibitions in regulation 15C are in summary:  

• humanitarian assistance activity 
• nuclear safety 
• extraordinary situation 
• medical goods or services 
• production or distribution of food 

Licensing grounds for provision of financial services relating to foreign exchange reserve and asset management

The purposes and activities for which OFSI may grant an individual licence in relation to the prohibitions on the provision of financial services for the purposes of foreign exchange reserve and asset management services to the National Bank of Belarus or the Ministry of Finance of the Republic of Belarus are in summary: 

• humanitarian assistance activity 
• financial regulation 
• financial stability 
• safety and soundness of a firm 
• extraordinary situation 
• insolvency

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. 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 (‘licensing considerations’). 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 trade sanctions until your licence has been granted.

The licensing considerations are navigable and scannable in a guide that forms part of this statutory guidance: Look up considerations for trade licences under the Belarus sanctions.

When you export or import goods, you may need to submit a declaration: guidance is available on:  

• how to make an export declaration. 
• how to make an import 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 the Export Control Joint Unit 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 Belarus, 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 Belarus.

3.5 Licensing for transport sanctions

Licences may also be issued for certain transport activities that would otherwise be prohibited by the Regulations. The Department for Transport (DfT) has overall responsibility for transport sanctions licensing. The Secretary of State for Transport is ultimately responsible for decisions to grant or refuse a transport sanctions licence in any individual case.

For some prohibitions there are some specific activities that DfT 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.

Prohibition description	Prohibition reference	Considerations for licensing
Prohibition on the movement of Belarusian aircraft	Regulation 29A	A licence may be granted for the overflight of UK airspace, or for the landing in the UK, of a Belarusian aircraft where it is necessary either: - for the delivery of humanitarian assistance, or - for the official purposes of a diplomatic mission or consular post in Belarus or the UK, or of an international organisation enjoying immunities in the UK in accordance with international law, or - for testing the aircraft for the purposes of providing technical assistance

You should not assume that a licence will be granted or engage in any activities prohibited by the sanctions until your licence has been granted.

A licence may be general or be issued to a particular category of person or to a particular person. Licences may contain conditions and they may be of a defined duration or of indefinite duration.

Information on how to apply for a transport sanctions licence is available on GOV.UK.

3.6 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

For specific queries about the sanctions regime, email: fcdo.correspondence@fcdo.gov.uk

For information about compliance with financial sanctions regulations, see Financial sanctions enforcement: case assessments and penalties. For specific queries, contact the Office of Financial Sanctions Implementation (OFSI).

To receive updates about export controls and trade sanctions, subscribe to Notices to Exporters. For specific queries, contact the Export Control Joint Unit (ECJU). For information about voluntary disclosure of a trade sanctions breach, or reporting a trade sanctions breach, see Export controls: military goods, software and technology.

You can also get help with exporting by contacting the Export Support Service.

For information about compliance with trade sanctions regulations, see Trade sanctions enforcement: case assessments and penalties. For specific queries, contact the Office of Trade Sanctions Implementation (OTSI).

For information about compliance with trade sanctions regulations for professional and business services and other standalone services see Apply for a licence to provide sanctioned trade services.

For information on import controls and prohibitions, see Notices to importers. For specific queries, contact: importsanctions@businessandtrade.gov.uk

For information about compliance with transport sanctions regulations: see Transport sanctions enforcement: case assessments and penalties. For specific queries contact: transportsanctions@dft.gov.uk

1. ‘the Goods Classification Table’ means the table so named in Annex I in Part Three of the Tariff of the United Kingdom. ↩